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Accuracy-Related
Addition to Tax Penalty
Year Deficiency Sec. 6651(a) Sec. 6662(a)
1992 $ 7,065 -- $1,413
1993 11,982 $1,325 2,396
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.
The issues for decision are: (1) Whether petitioner
Robert M. Johnson’s S corporation had unreported income for 1992
and 1993; (2) whether petitioner Robert M. Johnson’s
S corporation overstated a portion of its deductions for 1992 and
1993; (3) whether petitioners are entitled to additional itemized
deductions for 1992 and 1993; and (4) whether petitioners are
liable for the addition to tax and accuracy-related penalties.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners, former
husband and wife, resided in Florida. Hereinafter, all
references to petitioner in the singular are to Robert M.
Johnson.
During the years in issue, petitioner, an attorney, was the
sole shareholder of DUI Legal Centers, Inc. (DUI), an S law
corporation with multiple offices located in Tampa, Sarasota,
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Last modified: May 25, 2011