Herschel H. and Roberta S. Hoopengarner - Page 2

                                        - 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.             





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