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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.
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Last modified: May 25, 2011