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of $22,912.80. After concessions, the issues for decision are:
(1) Whether petitioners failed to report income reflected in bank
deposits controlled by them; (2) whether income reported on
Schedule C, Profit or Loss From Business, should be
recharacterized as wages and accompanying deductions disallowed;
(3) whether petitioners are liable for an addition to tax under
section 6651(a); and (4) whether petitioners are liable for an
accuracy-related penalty under section 6662(a).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. In
addition, because petitioners failed to comply with an order to
supplement their responses to respondent’s request for
admissions, some facts are deemed admitted pursuant to Rule 90.
Petitioners resided in Ottsville, Pennsylvania, at the time
they filed their petition.
Bradley Mark Cohen Enterprises, Inc.
Bradley M. Cohen (petitioner) was the sole shareholder and
sole corporate officer of Bradley Mark Cohen Enterprises, Inc.
(BMC), until its dissolution on December 31, 1994. During its
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