- 2 -
Alton and Mable Bean
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1987 $101,941 ---
1988 14,143 ---
1989 26,741 ---
1990 51,787 $10,357
1991 54,005 10,801
1992 39,656 7,931
Gary and Cynthia Bean
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1987 $ 3,041 ---
1988 3,056 ---
1989 8,891 ---
1990 24,575 $4,915
1991 31,999 6,400
1992 19,378 3,876
The issues for decision involve whether petitioners are
entitled to increased bases in their investments in an
S corporation as a result of (1) petitioners' personal guaranties
of the corporation's indebtedness on bank loans, (2) a transfer
of partnership assets to the S corporation, and (3) corporate
liabilities owed to a partnership. Also at issue is whether
petitioners are liable for the accuracy-related penalties.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Alton Bean, decedent, died in January of 1999 in Amity,
Arkansas. Decedent and petitioner Mable Bean were husband and
wife and the parents of petitioner Gary Bean. Petitioners Gary
and Cynthia Bean are husband and wife. At the time the petitions
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011