- 2 - Year Deficiency Accuracy-Related Penalty 1993 $51,860 $4,720 1994 122,417 10,647 The issues remaining for decision are: (1) Are petitioners required to utilize a 3-year recovery period as contended by petitioners or a 5-year recovery period as contended by respondent in calculating depreciation deductions for the years at issue for certain aircraft parts purchased during those years? We hold that they are required to use a 5- year recovery period. (2) Are petitioners liable for the accuracy-related penalty under section 6662(a) for each of the years at issue? We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated and are so found. In addition, on December 1, 1998, respondent filed a request for admissions with the Court, a copy of which the Court served on petitioners on December 4, 1998. On December 4, 1998, the Court ordered petitioners to file a response to that request on or before January 4, 1999. Petitioners did not file any response to respondent’s request for admissions. As a result, each matter set forth in respondent's request for admissions is deemed admitted. See Rule 90(c); Marshall v. Commissioner, 85 T.C. 267, 272 (1985). Petitioners resided in Adelanto, California, at the timePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011