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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 time
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