- 2 - also transferred funds from this account to the accounts of C-Co. and X-Co. to allow other family members to use the funds for personal purposes. P reported all receipts from his accounting services on J-Co.’s return, then deducted all business and personal items therefrom, disguising most of the items as “cost of goods sold”. J-Co. paid no tax. P did not report any income from J-Co. on his return for 1994, nor did he report income from the payment of personal expenses. Held: J-Co. is a sham, and we disregard it for tax purposes. Petitioner’s gross receipts, less allowable business expenses, are includable in his income. Held, further: P is liable for the fraud penalty under sec. 6663, I.R.C. Joseph J. House, pro se. John J. Comeau, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: These cases are before the Court consolidated for purposes of trial, briefing, and opinion. Joseph J. House (petitioner) and Joseph J. House, Inc. (JJH) separately petitioned the Court to redetermine respondent’s determinations of the following deficiencies in Federal income tax, addition to tax, and accuracy-related penalties: Joseph J. House, docket No. 8664-98 Accuracy-related penalty Year Deficiency Sec. 6662(a) 1994 $32,921 $6,584Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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