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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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