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subsequent section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
In a notice of deficiency, respondent determined that
petitioner is liable for deficiencies in Federal income taxes for
the tax years 1994 and 1995 in the amounts of $3,014 and $31,949,
respectively. Respondent also determined accuracy-related
penalties under section 6662(a) for the tax years 1994 and 1995
in the amounts of $603 and $6,343, respectively.
After concessions made by petitioner,1 the issues for
decision are: (1) Whether petitioner is entitled to deduct on
his 1994 Federal income tax return his pro rata share of
partnership loss attributable to a bad debt, and (2) whether
petitioner is liable for accuracy-related penalties under section
6662(a) for the tax years 1994 and 1995.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Dewitt, Michigan.
1 Petitioner concedes all adjustments to income in the
notice of deficiency, except the disallowed partnership loss
deduction of $65,419 and accuracy-related penalties which are the
issues before us. There appears to be a mathematical error in
the partnership loss deduction amount; the correct amount should
be $64,559.
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