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Edward DeFranceschi, David Klemm, and Jason Bell, for
petitioner.
Louise R. Forbes, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined the following
deficiencies and penalty with respect to petitioner’s Federal
income taxes for the calendar years 1996 and 1997:
Penalty
Year Deficiency I.R.C. Sec. 6662
1996 $1,044,037 $106,877.80
1997 1,817 --
After concessions by the parties, the principal issues for
decision are:
(1) Whether payments received by petitioner under preneed
funeral contracts are includable in gross income during the year
of receipt or during the year in which the goods and services are
provided by petitioner; and
(2) whether petitioner is liable for the section 6662
accuracy-related penalty.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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