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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1992 $57,466 $11,493
1993 39,669 7,934
1994 7,161 1,432
1995 36,098 7,220
After concessions, the issues for decision are:
(1) Whether petitioner is entitled to deduct trade or
business expenses under section 162 with respect to his Villa Del
Mar hotel venture for 1992, 1993, 1994, and 1995. We find he is
entitled to deduct some of the expenses.
(2) Whether petitioner is entitled to a claimed loss
deduction for 1992 from Amazona Enterprises, Inc. (Amazona), his
wholly owned S corporation. We find that he is not.
(3) Whether petitioner is entitled to claimed partnership
loss deductions for 1992 and 1994 from Roadmaster Leasing. We
find that he is not.
(4) Whether petitioner is liable for an accuracy-related
penalty under section 6662(a) for substantial understatement of
income tax for 1992, 1993, 1994, and 1995. We hold that he is
liable for a penalty in 1992 for the understatement attributable
to his disallowed Villa del Mar business expenses and his
disallowed loss deductions from Amazona and Roadmaster Leasing,
in 1993 for the understatement attributable to his disallowed
Villa del Mar business expenses, and in 1995 for his disallowed
Villa del Mar business deductions.
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Last modified: May 25, 2011