- 3 - 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.Page: 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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