- 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