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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.
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