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HJA, Inc., & Subsidiaries, Docket No. 22920-97
Year Deficiency
1991 $6,473
1992 83,578
1993 253,656
Following concessions,3 the issues for decision are:
1. Whether payments made by HJA, Inc., in connection with
an option and stock purchase agreement that were applied to
certain liabilities are taxable to Henry and Esther Misle as
ordinary income and deductible by petitioner HJA, Inc., &
Subsidiaries;
2. whether petitioner Henry Misle may reduce, for income
tax purposes, the gross amount of the option price paid to him or
for his benefit pursuant to the option and stock purchase
agreement by $150,000;
3. whether petitioners Henry and Esther Misle are liable
for accuracy-related penalties for tax years 1989 through 1994
and 1996 under section 6662(a);
4. whether petitioner Henry Misle is liable for an addition
to tax under section 6651(a) for failure to file a return for tax
year 1995; and
3The parties have settled most of the issues raised in the
notices of deficiency issued to petitioners. The only other
issues to be resolved are computational.
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