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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.
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