Robert L. Beck - Page 3




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          all years in issue, and asserted in the alternative accuracy-               
          related penalties under section 6662(a), as follows:                        
                                              Penalties                               
                              Year           Sec. 6662(a)                             
                              1991           $10,046                                  
                              1992           10,010                                   
                              1993           11,783                                   
                              1994           16,758                                   
                              1995           15,927                                   
               In his answer to Marguerite Beck’s (Mrs. Beck’s) amended               
          petition, respondent conceded the additions to tax under section            
          6651(f) for fraudulent failure to file and asserted in the                  
          alternative additions to tax for failure to file pursuant to                
          section 6651(a)(1) as follows:                                              
                                        Additions to Tax                              
                              Year        Sec. 6651(a)(1)                             
                              1991           $10,918                                  
                              1992           10,261                                   
                              1993           12,512                                   
                              1994           17,223                                   
                              1995           19,097                                   
               After concessions, the issues to be decided are:                       
          (1) Whether Dr. Beck is entitled to dental-practice business                
          deductions greater than respondent has allowed; (2) whether for             
          years 1993, 1994, and 1995, Dr. Beck is entitled to claimed                 
          losses allegedly arising from a horse operation; (3) whether Dr.            
          Beck is entitled to claimed net operating loss carryovers;                  
          (4) whether Dr. Beck’s income from his dental practice and from             
          oil royalties constitutes community property, taxable one-half to           
          each petitioner for each year in issue; (5) whether Mrs. Beck               






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