- 4 - Eugene A. Beck docket Nos. 12215-99, 12216-99 Penalty Year Deficiency Sec. 6663(a) 1991 $28,517.92 $21,388.44 1992 41,509.00 31,131.75 1993 30,649.00 22,986.75 Beck's Village West Liquors, Ltd. docket No. 12217-99 Penalty Year Deficiency Sec. 6663(a) 1991 $44,274.16 $32,127.00 1992 23,047.49 17,285.62 1993 37,064.66 26,407.50 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are as follows:2 1. Whether Beck's Village West Liquors, Ltd. (Beck's Liquors or the corporation) is liable for the fraud penalty under section 6663(a) for each of the years at issue. We hold that it 2Respondent determined that Beck's Liquors overstated its cost of goods sold in the respective amounts of $3,014 and $11,474 on its 1991 and 1993 Federal corporate income tax returns and understated its cost of goods sold in the amount of $39,004 on its 1992 Federal corporate income tax return. Petitioners do not contest those adjustments. Additionally, the notices of deficiency contain adjustments to Beck's Liquors deductions for charitable contributions and to Mr. Beck's taxable Social Security benefits. These are computational adjustments which will be affected by the outcome of the other issues to be decided, and we do not separately address them.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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