- 2 - Additions to tax and penalties Year Deficiency Sec. 6651(a)(1) Sec. 6661(a) Sec. 6662(a) 1985 $27,673 $3,362 $6,918 -- 1987 21,865 2,722 5,466 -- 1989 10,017 –- –- $2,003 1990 50,643 10,910 –- 10,129 Respondent filed an amended answer asserting that petitioners’ tax liability is as follows:1 Additions to tax and penalties Year Deficiency Sec. 6651(a)(1) Sec. 6661(a) Sec. 6662(a) 1985 $27,642 $3,889 $3,888 -- 1987 21,865 2,935 2,935 -- 1989 10,017 2,420 –- $1,936 1990 50,643 10,911 –- 10,129 After concessions, the issues for decision are: 1. Whether petitioners have a basis of $233,408 in additions to a building. We hold that their basis in the additions is $20,000. 2. Whether petitioners have a basis of $130,000 (or any other amount) in real property for two outdoor advertising signs on the property. We hold that they do not. 3. Whether the Babcock Road and Warfield Drive properties qualify under section 1033 as replacement property for property sold under threat of condemnation. We hold that they do not. 4. Whether petitioner placed certain vehicles in service when he bought them for his business, as respondent contends, or when he began to use them in his business, as petitioners 1 Respondent bears the burden of proof with respect to new matter alleged in the amended answer. Rule 142(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011