- 2 - The issues for our consideration are: (1) Whether petitioners’ 1991, 1992, and 1993 income was underreported in the amounts of $28,195, $22,695, and $74,013, respectively; (2) whether petitioners are entitled to a 1992 bad-debt deduction under section 166;1 (3) whether petitioners are entitled to a 1992 casualty loss deduction under section 165; (4) whether petitioners’ 1992 gain from the sale of Glenwood Wrecker Service was understated in the amount of $10,635; and (5) whether petitioners are liable for the accuracy-related penalty under section 6662(a) for the 1991, 1992, and 1993 tax years. FINDINGS OF FACT2 When their petition was filed, petitioners Glenn H. and Diane J. Flood resided in Chatsworth, Georgia. Glenn H. Flood (petitioner) owned two businesses during the years in question, Flood’s Auto Parts (FAP) and Glenwood Wrecker Service (Glenwood). FAP During the tax years in issue petitioner owned and operated FAP, a sole proprietorship located in Chatsworth, Georgia. FAP consisted of the wholesale and retail sale of auto parts, a wrecker service, and the sale of junk cars to a scrap metal 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable periods under consideration, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 The parties’ stipulation of facts and exhibits is incorporated herein by this reference.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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