- 2 -
Penalty, I.R.C.
Year Deficiency Sec. 6662(a)
1993 $135,811 $2,815.80
1994 3,628 725.60
1995 16,088 2,042.20
After concessions by the parties, the issues remaining for
decision are: (1) Whether the monetary transfers that
petitioners made to a corporation are capital contributions or
are bona fide debts that are deductible as business bad debts
under section 166 when they became worthless; (2) whether the net
profits and losses of petitioners’ fireworks businesses are
attributable to Mr. Dunnegan or Mrs. Dunnegan for purposes of
self-employment tax; and (3) whether payments made to a
charitable organization are business expenses or charitable
contributions.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Gerald L. and Erma L. Dunnegan (petitioners) resided in
Wichita, Kansas, when their petition was filed. Petitioners
filed joint Federal income tax returns for the years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011