- 2 - accuracy-related penalties under section 6662(a).1 The amounts of these determinations are as follows: Accuracy-related penalty Year Deficiency sec.6662(a) 1991 $125,996 - 0 - 1993 69,018 $13,804 1994 581,181 116,236 1995 2,247 449 Following concessions, we must decide: 1. Whether certain transactions increased the basis of Jerry L. Thomas (Jerry) in two S corporations named Ram Extrusions, Inc. (Ram), and Innovative Fibers, Inc. (Innovative), and one limited liability company named Twist-Tex, LLC (Twist- Tex). 2. Whether certain payments made to Jerry in connection with his sale of his interest in Conquest Carpet Mills, Inc. (Conquest), are taxable as capital gains or ordinary income. 3. Whether petitioners are liable for the accuracy-related penalties respondent determined for 1993 and 1994. FINDINGS OF FACT Some facts were stipulated. We incorporate herein by this reference the parties’ stipulation of facts and the exhibits submitted therewith. We find the stipulated facts accordingly. Petitioners are married individuals who filed joint Federal 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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