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Accuracy-Related
Additions To Tax Penalty
Year Deficiency Sec. 6651(a)(1)Sec. 6654 Sec. 6662(a)
1989 $36,815 $9,204 $2,492 $7,363
1990 21,990 5,498 1,447 4,398
1991 15,062 3,766 867 3,012
1992 22,471 5,618 979 4,494
1993 26,804 5,361 1,122 5,361
After settlement of a number of issues, the issues for
decision involve a claimed capital loss for 1990 of $8,275, a
claimed capital loss for 1991 of $47,391, and the late filing
additions to tax under section 6651(a)(1) for each of the years
shown in the schedule above.
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.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Melville, New York. From 1987 to 1989, petitioner was the sole
shareholder of three S corporations, namely, Papa Angelos Home
and Car Audio Inc. of Coram, Inc. (Car Audio), Papa Angelos
Discount Car Stereo, Inc. (Car Stereo), and Mobile Audio
Distributors, Inc. (Audio Distributors).
In 1987 and 1988, a downturn in the economy occurred and
affected the automobile accessory parts industry in which
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