Larry Dean Sykes and Ruby Sykes - Page 22




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          B.   The Amount of Petitioner’s Cash Hoard                                  
               We find that petitioner saved $7,000 from 1966 to 1971.  For           
          reasons discussed above at paragraph A-4, we believe that                   
          petitioner saved substantially less than the amounts he claimed             
          from his International Paper wages, the sale of his personal                
          possessions, and his buying and selling activity.  Thus, we find            
          that he saved about one-fourth of his International Paper wages             
          ($24,500), $2,000 from selling his personal possessions in 1985,            
          and about one-fourth of his total adjusted gross income from 1989           
          to 1997 ($6,500) from his buying and selling activity.  Upon due            
          consideration of the findings of the District Court, we conclude            
          that petitioner had a cash hoard of $40,000 ($7,000 + $24,500 +             
          $2,000 + $6,500) on December 31, 1996, and that petitioners had             
          unreported taxable income of $109,200 in 1997 from petitioner’s             
          participation in the fencing operation.                                     
          C.   Whether Petitioners Are Liable for the Accuracy-Related                
               Penalty                                                                
               Respondent contends that petitioners are liable for the                
          accuracy-related penalty for negligence and substantial                     
          understatement under section 6662(a) for 1997.                              
               Taxpayers are liable for a penalty equal to 20 percent of              
          the part of the underpayment attributable to negligence or                  
          disregard of rules or regulations or to a substantial                       
          understatement of income tax.  See sec. 6662(a) and (b)(1) and              
          (2).  Negligence includes failure to make a reasonable attempt to           





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