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Respondent determined deficiencies in petitioner's Federal
income taxes and accuracy-related penalties as follows:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1995 $31,272 $6,254
1996 24,507 4,901
1997 16,344 3,269
After concessions by the parties, noted hereafter, the
issues for decision are: (1) Whether petitioner is entitled to a
reduction in the amount of unreported gross receipts determined
by respondent in connection with petitioner's trade or business
activity for the years in question, and (2) whether petitioner,
for said years, is liable for the accuracy-related penalties
under section 6662(a).
During the years at issue, petitioner owned and operated a
funeral home as a self-employed activity. He is a licensed
embalmer, mortician, and funeral director. The business
originated with his father in 1950. Petitioner grew up working
in the business. He attended mortuary school at Cincinnati,
Ohio, graduated in 1976, and, in due course, became certified as
a mortician. He returned to his father's funeral home, and his
entire career has been with that business. Petitioner's father
died in 1981, leaving his widow and two sons, petitioner and
Allan Henry (Allan). Their mother donated the funeral home to
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