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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
$16,495.
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.
Background
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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