- 2 - Accuracy-Related Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1994 $5,054 -0- $892 1995 8,413 $234 906 1996 7,828 -0- 870 1997 34,289 -0- 6,858 1998 14,354 -0- 2,871 1999 8,974 -0- 1,795 The issues for decision are: (1) Whether petitioners are entitled to carry forward claimed net operating losses (NOLs) for 1994, 1995, 1996, 1997, 1998, and 1999; (2) whether petitioners are entitled to deduct claimed Schedule C expenses for 1994 and 1995; (3) whether petitioners are liable for an addition to tax pursuant to section 6651(a)(1)1 for 1995; and (4) whether petitioners are liable for an accuracy-related penalty pursuant to section 6662(a) for 1994, 1995, 1996, 1997, 1998, and 1999. These issues arise primarily from facts surrounding claimed net operating loss deductions that were allegedly generated when numerous banks foreclosed on five properties that petitioners had been developing for commercial use. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are 1 Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code as in effect for the years in issue. All amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011