Henry and Esther Misle - Page 3




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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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