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petitioners are liable for the section 6662(a) accuracy-related
penalty for 1996.1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Hillsdale, Wyoming, on the date the petitions were filed in these
cases.
During the years in issue, petitioner was engaged in the
business of installing bleachers as a sole proprietor.
Petitioner filed an individual Federal income tax return for
taxable year 1995. Petitioners were married in 1996 and filed
joint Federal income tax returns in 1996 and 1997.
Unreported Income
With respect to petitioner’s sole proprietorship,
petitioners reported business gross income of $140,559 in 1995
and $189,159 in 1996. Respondent determined that there was
unreported business income of $13,153 in 1995 and $38,641 in
1996. The notices of deficiency include no details concerning
the source of the unreported business income. Respondent also
1Petitioners generally do not dispute, and we do not
address, those adjustments by respondent which favor petitioners.
Although the parties addressed at trial the meal and
entertainment expense deductions, the adjustments with respect
thereto are in petitioners’ favor and need not be addressed here.
Adjustments to self-employment income taxes and deductions
therefor in each year in issue, and to the earned income credit
in 1996, are computational and will be resolved by the Court’s
holding on the issues in these cases.
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Last modified: May 25, 2011