Edward P. Knoll and Mary K. King-Knoll - Page 2

                                        - 2 -                                         
                                                  Penalty                             
               Year           Deficiency             Sec. 6662                        
               1993           $18,873                  $3,775                         
               1994           47,756                   9,551                          
               1995           51,584                   10,317                         
               The issues presented for our consideration are:  (1) Whether           
          a $116,000 settlement payment is excludable from gross income               
          under section 104(a)(2);1 (2) whether $48,4202 in payments was              
          nontaxable loans or taxable advances; and (3) whether petitioners           
          are subject to section 6662(a) penalties for substantial                    
          understatement of tax or negligent disregard of the rules and               
          regulations.  To the extent that we hold amounts are includable             
          in gross income, petitioners do not contest that such income is             
          subject to self-employment tax.                                             
                                  FINDINGS OF FACT3                                   
               Petitioners Edward P. Knoll and Mary King-Knoll resided in             
          Barrington, Illinois, at the time their petition was filed.                 
          During 1965, following his graduation from Northwestern                     




               1 All section references are to the Internal Revenue Code in           
          effect for the years at issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  
               2 If the $116,000 and/or $48,420 amounts are includable in             
          income, we must also decide the proper year for inclusion.                  
               3 The parties’ stipulation of facts is incorporated by this            
          reference.                                                                  





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