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Accuracy-Related Penalty
Year Deficiency Sec. 6662
1996 $6,719 $1,344
1997 6,437 1,287
1998 8,635 1,727
Respondent determined deficiencies in Federal income tax for
petitioner Amnesty International as follows:
Year Deficiency
1996 $5,200
1997 5,466
1998 10,173
With respect to Darlene Esposito (petitioner) the issues for
decision are: (1) Whether petitioner is entitled to a capital
loss deduction of $3,000 for 1996, 1997, and 1998; (2) whether
petitioner is entitled to deduct for 1998, business expenses of
$5,494 claimed on Schedule C, Profit or Loss From Business; (3)
whether petitioner is entitled to cost of goods sold of $10,685
for 1998; (4) whether petitioner is liable for self-employment
tax for 1998; (5) whether it was proper for petitioner to claim
the earned income credit for 1996 and 1997; (6) whether it was
proper for petitioner to claim prepayment credits from regulated
investment companies for 1996, 1997, and 1998; and (7) whether
petitioner underpaid her tax due to negligence or intentional
disregard of rules or regulations.
The issue for decision as far as petitioner Amnesty
International (Amnesty) is concerned is whether Amnesty is
entitled to prepayment credits from regulated investment
companies in each of the years 1996, 1997, and 1998.
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Last modified: May 25, 2011