- 2 - I.R.C., accuracy-related penalty on grounds of failure to prove that they acted with reasonable cause and good faith with respect to their substantial understatement of income tax for 1994 and 1995. Daniel C. Ertel, for petitioners. Lydia A. Branche, for respondent. MEMORANDUM OPINION NIMS, Judge: Respondent determined the following deficiencies and penalties with respect to petitioners’ Federal income taxes for the taxable years 1994 and 1995: Year Deficiency Penalties Sec. 6662(a) 1994 $30,096 $6,019 1995 179,066 35,813 Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years in issue. After concessions by petitioners the issues remaining for decision are: (1) Whether a section 1231 gain in the amount of $774,982 was realized and should be recognized, alternatively, in 1993 or 1994; and (2) whether petitioners are liable for section 6662(a) penalties in 1994 and 1995.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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