- 2 - accuracy-related penalties under section 6662(a), and fraud penalties under and 6663(a):1 Years Deficiencies Sec. 6662(a) Sec. 6663(a) 1993 $11,886 $251 $7,972 1994 13,286 441 8,309 1995 15,576 94 11,255 Following respondent’s concession in answer that petitioners are not liable for the fraud penalties under section 6663(a), and respondent’s allegation in answer that petitioners are liable for the accuracy-related penalties under section 6662(a) as to the entire deficiencies, we decide primarily whether petitioners underreported their sole-proprietorship gross receipts by $33,599, $37,317, and $51,955.2 We hold they did. We decide secondly whether petitioners are liable for the accuracy-related penalties under section 6662(a). We hold they are liable only for the amounts determined under section 6662(a) in the notice of deficiency. FINDINGS OF FACT Some facts have been stipulated and are so found. The stipulated facts and exhibits submitted therewith are 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the subject years, Rule references are to the Tax Court Rules of Practice and Procedure, and dollar amounts are rounded. 2 Respondent’s allegation in answer as to the increased liability under sec. 6662(a) relates solely to the unreported gross receipts.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011