James J. Coyle - Page 5

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          Regal is not entitled to a claimed deduction for State sales tax            
          for its tax years ending March 31, 1992 and 1993, of $12,740 and            
          $15,844, respectively; Regal failed to report volume rebate                 
          income for its tax year ending March 31, 1993, of $31,713; and              
          Mr. Coyle failed to report dividend income from Regal in 1992 of            
               Regal and Mr. Coyle did not present any evidence concerning            
          these determinations.  To some extent the adjustments to the                
          claimed carryback and carryforward are affected by our findings             
          and conclusions on the issues placed in dispute.  To the extent             
          they are not affected by the issues placed in dispute, we deem              
          these determinations conceded.                                              
               The notice of deficiency mailed to Mr. Coyle increased the             
          self-employment tax in 1992 and 1993 and decreased the earned               
          income credit (EIC) in 1992 by $18.  These computational                    
          adjustments depend on the adjustments to income for 1992 and                
          1993.  Mr. Coyle has not disputed these adjustments.  Therefore,            
          we do not separately address them.                                          
               Some of the facts have been stipulated and are so found.  At           
          the time the respective petitions in these cases were filed, Mr.            
          Coyle was a resident of Lakeland, Florida, and Regal’s principal            
          place of business was Lakeland, Florida.                                    

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