- 2 - 1989 -- -- -- -- $11,746 1 Fifty percent of the statutory interest on $18,234, computed from Apr. 15, 1988, to the earlier of the date of assessment or the date of payment. All section references are to the Internal Revenue Code in effect for the years in issue. The issues for decision are as follows: 1. Whether petitioners failed to report capital gain and rental income and overstated depreciation expenses and charitable contributions. We hold that they did. 2. Whether petitioners are liable for section 6653 additions to tax, and a section 6663 penalty, for fraud. We hold that they are. FINDINGS OF FACT Petitioners, husband and wife, resided in Kalamazoo, Michigan, at the time their petition was filed. During the years in issue, Mr. Shah worked as a scientist, and Mrs. Shah as a research biochemist, for The Upjohn Company (Upjohn). Upjohn provided petitioners with medical insurance and reimbursed petitioners' employee business expenses. Petitioners were involved in real estate activities. They jointly owned and managed two rental properties. Petitioners also owned a vacant lot, which they purchased in 1984 for $16,000. Petitioners, in 1986, sold the lot on an installment basis for $26,000 and, in 1987, received a $17,693 payment.Page: Previous 1 2 3 4 5 Next
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