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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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