-2- penalties for negligence under section 6662(a) for each of these years. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Amounts are rounded to the nearest dollar. Miriam Stanley is a party to this action by reason of having filed income tax returns jointly with petitioner Richard T. Stanley, Sr. References hereinafter to petitioner relate to Mr. Stanley. This case was submitted to the Court without trial pursuant to Rule 122(a). After moving jointly to submit this case for trial on the basis of the pleadings and the facts recited and the exhibits in the stipulation of facts, petitioners' attorney was ordered to file a brief no later than November 13, 1998. Despite repeated admonitions that the brief was required and overdue, petitioner's attorney has failed to file with the Court his brief in this matter. We must decide the case, therefore, on the record before us, without benefit of petitioner's arguments. Following concessions by the parties, we must decide whether petitioner is entitled to deduct nonbusiness bad debts of $498,500 for 1993. We must also decide whether petitioner is entitled to deduct business bad debts of $2,041,409 for 1994. Finally we must decide whether petitioner is subject to accuracy-related penalties for negligence pursuant to section 6662(a) for the years 1992 through 1994. We hold that petitioner is not entitled to the contested deductions and that petitionersPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011