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income tax and imposed a section 6662(a) penalty of $1,495.5
The deficiency apparently results from, or is largely
attributable to, the disallowance of a claimed charitable
contribution deduction for the donation of whale meat to certain
native Alaskan tribal communities and the disallowance of
deductions for expenses incurred in connection with whaling
activity.
On August 17, 1992, the deficiency and penalty were
assessed, as was interest of $2,348.31.
On February 1, 1993, an untimely petition was filed with
this Court (docket No. 2198-93) in response to the above-
referenced notice of deficiency. Because the petition was not
filed within the period prescribed by section 6213(a), upon
respondent’s motion that case was dismissed for lack of
jurisdiction on that ground on April 13, 1993.
Including tax, additions to tax, penalties, and interest, as
of March 26, 1993, all but $8.61 of petitioners’ 1989 liability
had been paid. Because this amount is what respondent refers to
as “below tolerance”, respondent did not issue a notice and
demand for the $8.61.
5 A copy of the notice of deficiency has not been included
in the record, but it appears that in that notice respondent also
determined a deficiency in petitioners’ 1988 Federal income tax.
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