- 3 - Kelso in the form of roofing services Kelso provided to Badell in B&W’s 1995 fiscal year. We hold that it did. 2. Whether B&W may deduct costs it advanced on behalf of its clients of $24,680 for fiscal year 1995 and $37,799 for fiscal year 1996. We hold that it may not. 3. Whether petitioners Patrick Badell and Lillian Badell (the Badells) and petitioners Ronald Wilson and Donna Wilson (the Wilsons) are liable for the accuracy-related penalty for negligence under section 6662(a) for 1994, 1995, and 1996. We hold that they are. Section references are to the Internal Revenue Code in effect during the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. References to Badell and Wilson are to Patrick Badell and Ronald Wilson, respectively. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioners The Badells lived in Indianapolis, Indiana, when they filed their petition. The Wilsons lived in Rushville, Indiana, when they filed their petition. B. Badell & Wilson, P.C. Badell and Wilson are attorneys. They each own 50 percent of the stock of B&W, an S corporation incorporated on June 3, 1982. B&W’s office is located in Rushville. Badell was B&W’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011