- 2 - penalties for tax years ending May 31, 1990, 1991, and 1992 as follows: Best Auto Sales, Inc. Accuracy- Related Penalty Year Ending Deficiency Sec. 6662(a) May 31, 1991 $79,787 $15,957 May 31, 1992 15,413 –- ABC Autos, Inc. Accuracy- Related Penalty Year Ending Deficiency Sec. 6662(a) May 31, 1990 $97,851 $19,570 May 31, 1991 58,432 11,686 May 31, 1992 81,560 16,312 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 primary issues for decision are: (1) Whether petitioners are entitled to bad debt deductions with respect to certain automobile loans; (2) Whether petitioner ABC Autos, Inc., is entitled under sections 1.471-2(c) and 1.471-4(c), Income Tax Regs., to claimed write-downs of its used automobile inventory to the lower of cost or market; andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011