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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1991 1$30,573.69 $6,115
1992 27,729.42 1,546
1Respondent determined a deficiency of $21,371.69 in Federal
income tax and $9,202 in self-employment tax.
2Respondent determined a deficiency of $2,389 in Federal
income tax, $3,956.42 in self-employment tax, and an earned
income credit recapture of $1,384.
The issues for decision are:
(1) Whether petitioners had unreported net income from a
sports memorabilia activity in the amounts of $96,350 in 1991 and
$28,001 in 1992;
(2) whether petitioners are liable for self-employment tax
on the net income from the sports memorabilia activity;
(3) whether petitioners are liable for the accuracy-related
penalties under section 6662(a); and
(4) whether petitioner Barbara Kling is eligible for relief
under section 6015 with respect to any understatement of tax
attributable to the sports memorabilia activity.
FINDINGS OF FACT
A. Background
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference.
Petitioners Raymond F. Kling (Raymond) and Barbara K. Kling
(Barbara) resided in Cleveland, Ohio, when their petition was
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