Dennis and Dorinda J. Jelle - Page 2




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                    Held, further, Ps are liable for the sec. 6662(a),                
               I.R.C., accuracy-related penalty on grounds of a                       
               substantial understatement of income tax.                              

               Gregory W. Wagner, for petitioners.                                    
               Michael J. Calabrese and Mark J. Miller, for respondent.               



                                       OPINION                                        

               NIMS, Judge:  Respondent determined a Federal income tax               
          deficiency for petitioners’ 1996 taxable year in the amount of              
          $46,993.  Respondent further determined an accuracy-related                 
          penalty of $9,399, pursuant to section 6662(a).  The issues for             
          decision are:                                                               
               (1) Whether petitioners are required to recognize income in            
          1996 from cancellation of indebtedness;                                     
               (2) whether petitioners must report as income amounts                  
          received in the form of Social Security benefits; and                       
               (3) whether petitioners are liable for the section 6662(a)             
          accuracy-related penalty on account of a substantial                        
          understatement of income tax.                                               
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the year at             
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     







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