- 2 - Penalty Year Deficiency Sec. 6662(b)(1) 1992 $19,181 $3,836 1993 24,707 4,941 Petitioners filed a petition to redetermine the deficiency and penalty for 1993 and a second petition to redetermine the deficiency and penalty for 1992. We consolidated these cases for purposes of trial, briefing, and opinion pursuant to Rule 141(a)1 because they present common questions of fact and law. For convenience, these cases hereinafter are referred to as this case. After concessions,2 the issues for decision are as follows: (1) Whether petitioners are entitled under section 162(a) to deductions claimed on Schedules C, Profit or Loss From Business, for 1992 and 1993 with respect to a purported restaurant/nightclub business and, if so, in what amounts; (2) whether petitioners are entitled under section 167 to deduct depreciation expenses claimed with respect to two 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2Respondent concedes that 25 percent of the building petitioner Oliver W. Wilson owned at 5401-9 S. Broadway was placed in service and used for rental purposes during 1991, 1992, and 1993.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