- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011