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6673(a)(1). All section references are to the Internal Revenue
Code in effect for 1998.
The issues for decision are: (1) Whether petitioners’
compensation for services, unemployment compensation, and
interest received during 1998 constitute gross income; (2)
whether petitioners are liable for an accuracy-related penalty
under section 6662(a); and (3) whether imposition of a penalty
under section 6673(a) is appropriate under the circumstances of
this case.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. Petitioners resided in
Fallbrook, California, when they filed their petition.
Petitioners are well-educated people. Both graduated from
California State University at Long Beach. Mark Corcoran
(petitioner) received a bachelor’s degree in business
administration with an emphasis in accounting. Petitioner Nancy
Corcoran (Mrs. Corcoran) holds a master’s degree in education.
Petitioner is an accountant for Global Outdoors, Inc. Mrs.
Corcoran teaches in the San Diego Catholic school system.
During 1998, petitioner received compensation for services
of $13,269 and $5,773 from All American Homes and Empire Marine,
Inc., respectively. Petitioner also received unemployment
compensation of $168 from the California Employment Development
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