Jerry J. and Susan N. LeBouef - Page 2




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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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