- 2 -
Internal Revenue Code for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
After concessions, the issues remaining for determination are
whether petitioners are: (1) Entitled to deduct, in 1991,
certain advances made to Jensen Talbert Fine Jewelers, Inc.
(JTFJ); (2) entitled to deduct, in 1991, payments made pursuant
to personal guaranties of JTFJ debt; and (3) liable for the
section 6662 accuracy-related penalty.
FINDINGS OF FACT
When the petition was filed, Larry and Diane Levy resided in
Newport Beach and Torrance, California, respectively.
I. Background
JTFJ owned and operated the Jensen Talbert Fine Jewelry
Store (the store). Robert Levy, Larry Levy’s father, was the
sole shareholder of JTFJ.
Prior to 1985, Diane Levy worked as a salesperson in the
store. In 1985, she began managing the store’s day-to-day
operations (i.e., she supervised employees, acted as lead
salesperson, and purchased inventory). Diane Levy received wages
of $7,838, $10,125, $6,160, $11,480, and $13,720 in 1982 through
1986, respectively.
Prior to 1985, Larry Levy began making advances to JTFJ. By
May 2, 1985, Larry Levy had advanced $53,250 to JTFJ. In 1985,
Larry Levy started working for JTFJ. He worked for JTFJ an
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011