- 2 - Respondent determined deficiencies in petitioners’ Federal income taxes, additions to tax, and penalties as follows: Additions to Tax Penalties Year Deficiency Sec. 6651(a)(1) Sec. 6662 1992 $25,952 $5,929 $5,190 1993 5,914 870 1,183 1994 12,751 2,597 2,550 The issues for decision for each year in issue are: (1) Whether petitioners underreported income; (2) whether petitioners are entitled to depreciation deductions greater than those respondent allowed; (3) whether petitioners are entitled to a deduction for charitable contributions; (4) whether petitioners had reasonable cause for their failure to file a timely Federal income tax return; and (5) whether the underpayment of tax required to be shown on petitioners’ Federal income tax return is due to negligence. Background Some of the facts have been stipulated and are so found. Petitioners are husband and wife. They filed an untimely Federal income tax return for each year in issue. At the time the petition was filed, they resided in Indianapolis, Indiana. William M. Hawkins (petitioner) is an attorney. He has practiced law since 1971 and did so as a sole practitioner during the years in issue. Petitioners’ Federal income tax return for each year in issue includes a Schedule C, Profit or Loss From Business, on which income and expenses attributable toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011