- 2 -
Additions to Tax Penalties
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6662(a) 6663(a)
1989 $12,411 --- --- $9,308
1990 39,796 --- --- 29,847
1991 50,239 $12,957 $84 37,366
All section references are to the Internal Revenue Code for
the years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure, unless otherwise indicated.
The issues remaining1 for our consideration are:
(1) Whether, for 1990 and 1991, petitioner is entitled to
Schedule C, Profit or Loss From Business, deductions in excess of
those allowed or conceded by respondent; (2) whether petitioner
is liable for the section 6663(a) fraud penalty for 1990 or 1991;
(3) alternatively, whether petitioner is liable for the section
6662(a) accuracy-related negligence penalty for 1990 or 1991; (4)
whether petitioner is liable for the section 6662(a) accuracy-
related negligence penalty for 1991 with respect to the portion
of the income tax deficiency that involves the omission of
interest income or a claimed loss from the sale of a taxi; and
1 Respondent conceded the income tax deficiency and the sec.
6663(a) penalty for petitioner’s 1989 tax year. For the 1991
taxable year, respondent conceded that petitioner is entitled to
Schedule C deductions in addition to those allowed in the notice
of deficiency. For 1991, petitioner claimed $254,787 in
deductions on his Schedule C, and respondent, in the statutory
notice of deficiency, allowed $112,023. During pretrial
activity, respondent conceded that, in addition to those allowed
in the notice of deficiency, petitioner is entitled to $45,184 of
business deductions.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011