- 2 - Held, further, Ps are liable for the sec. 6662(a), I.R.C., accuracy-related penalty. Larry D. Vince, for petitioners. Nguyen-Hong K. Hoang, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Judge: Respondent determined a Federal income tax deficiency for petitioners’ 1993 taxable year in the amount of $93,957. Respondent also determined an addition to tax of $23,161 pursuant to section 6651(a)(1) and an accuracy-related penalty of $18,791 under section 6662(a). The issues for decision are: (1) Whether petitioners, having reported gross receipts of $244,270 on their 1993 Schedule C, Profit or Loss From Business, are entitled to offset such receipts by an identical amount as cost of goods sold; (2) whether petitioners are entitled to deduct a claimed loss of $19,791; (3) whether petitioners are liable for the section 6651(a)(1) addition to tax for failure timely to file their 1993 income tax return; and (4) whether petitioners are liable for the section 6662(a) accuracy-related penalty.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011