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Penalty, I.R.C.
Year Deficiency Sec. 6663(a)
1993 $41,582 $31,187
1994 57,974 43,481
1995 346,400 259,800
After concessions, the issues for decision are: (1) Whether
petitioners are entitled to claim additional cost of goods sold
of $47,884 for 1995; (2) whether petitioner Alber I. Said
(petitioner) is liable for the fraud penalty under section
6663(a) for 1993, 1994, and 1995 or, in the alternative, liable
for an accuracy-related penalty under section 6662(a) for the
years in issue; and (3) whether petitioner Georgette H. Said
(Mrs. Said) is liable for the accuracy-related penalty under
section 6662(a) for the years in issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Moreno Valley, California, at the time
they filed the petition in this case.
Petitioner attended the College of Commerce at the
University of Alexandria, Egypt, and obtained a degree in
accounting. Petitioner owned and operated a gasoline station,
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