- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011