-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 petitioners
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011