- 2 -
Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1993 $40,764 $10,191 $8,153
1994 55,887 13,972 11,177
1995 288,098 71,855 57,620
All section references are to the Internal Revenue Code for
the years at issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
The issues for decision are: (1) Whether for 1995 petitioners
are entitled to the amount of cost of goods sold reported on
Schedule C, Profit or Loss From Business; (2) whether for 1993,
1994, and 1995 petitioners are entitled to Schedule C expense
deductions in excess of those amounts allowed by respondent; (3)
whether petitioners are liable for self-employment taxes; (4)
whether petitioners are liable for additions to tax under section
6651(a)(1) for 1993, 1994, and 1995; and (5) whether petitioners
are liable for the section 6662(a) accuracy-related penalty for the
substantial understatement of income tax as provided in section
6662(b)(2) for 1993, 1994, and 1995.
Additional adjustments made by respondent to petitioners’
exemptions, itemized deductions, and self-employment taxes are
computational and will be resolved by our holdings with respect to
the aforementioned issues.
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