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Penalty
Docket No. Year Deficiency Section 6662(a)
20218-98 1992 $34,515 $6,903
20219-98 1992 31,568 6,314
These cases have been consolidated for purposes of trial,
briefing, and opinion.
The issues for our consideration are: (1) Whether
petitioners Jeffrey Guerrero (Mr. Guerrero) and Alan Bone (Mr.
Bone) had sufficient bases in 1992 to deduct $106,487 and
$98,064, respectively, as their shares of the operating loss from
a subchapter S corporation, Olympic Concrete Pumping, Inc.
(Olympic); (2) whether Olympic’s 1992 income was understated by
$56,598 as the result of an error in converting book income to
taxable income; and (3) whether petitioners are liable for the
penalties under section 6662(a)1 for negligence.
FINDINGS OF FACT
We incorporate by this reference our findings of fact in
A.J. Concrete Pumping, Inc. v. Commissioner, T.C. Memo. 2001-42,
and Bone v. Commissioner, T.C. Memo. 2001-43.
Petitioners Jeffrey and Genedine Guerrero resided at 4215
Osprey Pointe, Woodstock, Georgia, on the date they filed their
petition in this case. Petitioners Alan and Kathleen Bone
resided at 617 North Lake Drive, Canton, Georgia.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the periods under
consideration.
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Last modified: May 25, 2011