- 2 - Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined the following deficiencies in petitioners’ Federal income taxes, addition to tax, and penalty, for the respective taxable years: Sec. 6651(a)(1) Sec. 6662(a) Docket No. Year Deficiency Addition to tax Penalty 2731-01S 1995 $2,259 $508 -0- 2730-01S 1996 24,448 -0- $4,890 2730-01S 1997 4,080 -0- -0- Unless otherwise indicated, references to petitioner with respect to any taxable year, and any references to petitioners with respect to 1995, are references solely to petitioner Robert J. Hartz. The issues for decision are: (1) Whether petitioners received unreported income in 1995 and 1996; (2) whether petitioners are entitled to certain disallowed business expense deductions in each year in issue, and to an additional deduction for interest expense in 1995; (3) whether petitioners are entitled to deduct a loss on the disposition of purported business property in 1997; (4) whether petitioner is liable for the section 6651(a)(1) addition to tax for failure to file timely his Federal income tax return in 1995; and (5) whetherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011