- 2 - Additions to Tax/Penalties Year Deficiency Sec. 6661(a) Sec. 6662 1987 $611,053 $152,763 - 1988 672,765 168,191 - 1989 113,278 - $22,656 1990 52,462 - 10,492 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are: (1) Whether amounts petitioners received from two insurance businesses were loans or were taxable distributions; (2) whether petitioners are entitled to deduct losses from fishing activities engaged in by Thomas O’Connell (petitioner) through two S corporations; and (3) whether petitioners are entitled to a business bad debt or a nonbusiness bad debt deduction. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioners resided in Chula Vista, California, at the time that they filed their petition in this case. During the years in issue, petitioner owned 75 percent of a corporation named Mayflower Insurance Agency, Inc. (Mayflower). Petitioner was president of Mayflower and in charge of itsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011