- 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.
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