- 2 -
Franklin W. Briggs
Penalties and Additions To Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6661
1986 $69,077$2,927 $37,536 ** -- $17,269
1987 10,875 (2,109)* 20,540*** $18,000 4,828
1988 20,490 -- -- -- -- 5,123
* The record does not conclusively establish the source of what is apparently
a penalty refund.
** 50 percent of the interest due on $50,048.
*** 50 percent of the interest due on $7,935.
Jimmy D. Morris and Sandra B. Morris
Penalties and Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6661
1986 $77,278 $6,928 $37,175 ** -- $19,320
1987 (1,048)* 4,489 26,613 *** -- 13,173
1988 2,606 -- -- -- $1,955 --
* The negative adjustment resulted from a net operating loss carryback from
1990.
** 50 percent of the interest due on $43,838.
*** 50 percent of the interest due on $8,207.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions,1 the issues for decision are:
1. The amount of ordinary income petitioners realized with
respect to certain gas rebate checks earned by their wholly
owned S corporation but received by petitioners individually;
1 The parties have stipulated various adjustments to
petitioners’ reported income. In addition, on brief petitioners
concede that for taxable year 1988 petitioners Franklin Briggs
(Briggs) and Jimmy Morris (Mr. Morris) each have additional
income of $36,000 from the proceeds of the sale of Association
Cable TV, Inc.’s (ACT’s) assets and of $40,200 from proceeds from
a covenant not to compete.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011