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Respondent determined deficiencies in petitioner's Federal
income taxes and accuracy-related penalties for the taxable years
in the amounts set forth below:
Penalty
Year Deficiency Sec. 6662(a)
1991 $2,967 $593
1992 4,563 913
1993 4,524 905
After concessions, the remaining issues for decision are:
(1) Petitioner's bases in Special Occasions, a partnership, for
the 1992 and 1993 tax years; (2) petitioner's bases in Special O,
Inc., an S corporation, for the 1991, 1992, and 1993 tax years;
(3) whether Special O, Inc., is entitled to claim travel expenses
for the 1991, 1992, and 1993 tax years; (4) whether Special O,
Inc., is entitled to expense certain depreciable business assets
pursuant to section 179 for 1993; and (5) whether petitioner is
liable for accuracy-related penalties pursuant to section 6662(a)
for the 1991, 1992, and 1993 tax years.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Oakland, California.
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