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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) whether
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