James J. Coyle - Page 3




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          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               Respondent determined that petitioners James J. Coyle (Mr.             
          Coyle) and Regal Mobile Home Sales, Inc. (Regal), in these                  
          consolidated cases are liable for deficiencies, an addition to              
          tax, and penalties as follows:                                              
                        James J. Coyle, docket No. 12012-99S                          
                                                  Penalty                             
                    Year           Deficiency         Sec. 6663                       
                    1992           $9,983         $7,487                              
                    1993           5,284          3,962                               
                 Regal Mobile Home Sales, Inc., docket No. 12061-99S                  
                                        Addition to Tax    Penalty                    
               Year         Deficiency    Sec. 6651(a)(1)   Sec. 6663                 
               3/31/90        $2,850              –         $2,138                    
               3/31/92        3,690               –         2,768                     
               3/31/93        3,526               –         2,645                     
               3/31/94        3,607          $902           2,705                     
               The issues for decision are:                                           
               (1) Whether Regal failed to report gross receipts from                 
          sales of mobile home wheels and axles for its tax years ending              
          March 31, 1992 and 1993, of $13,948 and $45,741, respectively.              
          Respondent also determined that Regal is entitled to a                      
          corresponding deduction for each year for commissions it paid               
          Mr. Coyle.  If we conclude that Regal omitted gross receipts from           
          sales of wheels and axles, then Regal is allowed the                        






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