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Petitioner Simco Automotive Pump Co., Inc. (Simco):
Fraud penalty
Fiscal year Deficiency sec. 6663
June 30, 1990 $24,453 $18,340
June 30, 1991 27,225 20,419
Petitioner John R. MacLean (John):
Fraud penalty
Year Deficiency sec. 6663
1989 $2,423 $4,464
1990 --- 16,664
1991 11,089 18,332
Unless otherwise noted, 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.
We must decide the following issues:
(1) Whether John had unreported income in the amounts of
$9,905 in 1989 and $34,731 in 1991. We hold that he did.
(2) Whether Simco is entitled to deduct, as compensation,
certain income received by John resulting from sales of scrap
metal. We hold that Simco is not.
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Last modified: May 25, 2011