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contend. We hold that petitioner placed the vehicles in service
when he bought them for his business.
5. Whether petitioners may deduct depreciation for their
business property in an amount greater than respondent allowed.
We hold that they may not.
6. Whether petitioners may claim net operating loss
carrybacks or carryforwards or investment tax credit
carryforwards for the years in issue. We hold that they may not.
7. Whether petitioners are liable for an addition to tax
under section 6651 for failure to timely file their Federal
income tax returns for the years in issue. We hold that they
are.
8. Whether petitioners are liable for additions to tax for
substantial understatement of income tax under section 6661 for
1985 and 1987 and for accuracy-related penalties for substantial
understatement of tax under section 6662(b)(2) and (d) for 1989
and 1990. We hold that they are for the years they substantially
underpaid tax.
References to petitioner are to Thomas C. Sandoval, Jr.
Section references are to the Internal Revenue Code in effect
during the years in issue. Unless otherwise noted, Rule
references are to the Tax Court Rules of Practice and Procedure.
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