- 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;
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