- 2 - 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.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