- 3 - corresponding deductions. Regal does not dispute the allowance of the corresponding deductions. (2) Whether Mr. Coyle failed to report commission income from Regal for 1992 and 1993 of $21,130 and $18,816, respectively. (3) Whether Regal is liable for section 6663 civil fraud penalties for its tax years ending March 31, 1990, 1992, 1993, and 1994, of $2,138, $2,768, $2,645, and $2,705, respectively. (4) Whether Mr. Coyle is liable for section 6663 civil fraud penalties for 1992 and 1993 of $7,487.25 and $3,962.25, respectively. (5) Whether the periods of limitations for assessment of underpayments of tax with respect to Regal and Mr. Coyle have expired. Respondent also determined the following: Regal is not entitled to claim a net operating loss (NOL) carryback of $18,995 to its tax year ending March 31, 1990, from the tax year ending March 31, 1992; Regal is not entitled to claim an NOL carryforward of $24,048 to its tax year ending March 31, 1994; Regal failed to report rental or installment sale income in its tax year ending March 31, 1992, of $4,496; Regal is liable for an addition to tax under section 6651(a)(1) for its tax year ending March 31, 1994; Regal is not entitled to a claimed bad debt deduction for its tax year ending March 31, 1992, of $26,358;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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