- 2 - Additions to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6662 1989 $45,048 $9,010 -- $11,143 1990 40,128 10,032 $2,642 -- 1991 23,336 4,445 1,207 -- 1992 35,613 8,361 1,448 -- All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Petitioners, husband and wife, resided in Perrineville, New Jersey, at the time their petition was filed. In 1985, Mr. Provost and two other investors formed Sandew Homes, Inc. (Sandew), an S corporation. Mr. Provost guaranteed several mortgage loans relating to properties owned by Sandew. On their 1989 return, petitioners deducted a $159,565 ordinary loss, a $58,863 net operating loss carryforward from 1988, and $29,086 of mortgage interest payments, relating to Sandew. Petitioners filed their 1989 return on April 7, 1994. On July 12, 1993, petitioners filed a petition in the U.S. Bankruptcy Court for the District of New Jersey under chapter 11 of the U.S. Bankruptcy Code. Petitioners' bankruptcy action was converted from a chapter 11 to a chapter 7 case on July 11, 1994. On April 14, 1997, petitioners were discharged from bankruptcy.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011