Edward R. Stolz II - Page 3




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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations filed by the parties, with accompanying                    
          exhibits, are incorporated herein by this reference.                        
               Edward R. Stolz II resided in Sacramento, California, at the           
          time of filing his petition in this case.  Since the 1970s, he              
          has owned a radio station in Sacramento and has operated the                
          business as a sole proprietorship.  The disallowance of                     
          deductions taken with respect to this business, after an audit of           
          petitioner’s 1994 and 1995 income tax returns, underlies the                
          matter at hand.                                                             
               Prior to trial, the parties entered into a Stipulation of              
          Settled Issues and signed a Joint Status Report resolving the               
          majority of the points in controversy as follows:                           
                    Petitioner is not liable for any additional tax or                
               penalties for tax year 1994.                                           
                    Petitioner is liable for additional tax of                        
               $17,823.00 for tax year 1995.                                          
                    The parties have been unable to resolve whether                   
               petitioner is liable for the delinquency penalty under                 
               section 6651(a) and the accuracy-related penalty under                 
               section 6662(a) for tax year 1995.                                     
                    The parties request that this case be set for                     
               trial to resolve the two remaining issues.                             
          After recalculation based on these concessions, the amounts                 
          remaining at issue are $945 for the delinquency addition to tax             
          and $3,564.60 for the accuracy-related penalty, both with respect           
          to 1995.                                                                    







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