John and Yoon Ja Biazar - Page 2

                                        - 2 -                                         
          Additions to Tax          Penalties                                         
          Year    Deficiency      Sec. 6651(a)(1)         Sec. 6662(a)                
          1995     $78,073            $18,472               $15,615                   
          1996      55,863             13,053                11,173                   
          1997      71,468             17,061                14,294                   
          1998      41,628              ---                   8,326                   
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code, and all Rule references are to the Tax               
          Court Rules of Practice and Procedure.  All figures are rounded             
          to the nearest dollar.                                                      
               After concessions,1 the issues for decision are (1) whether            
          petitioners are entitled to deduct expenses related to 97 Cents             
          Market (minimart) in amounts greater than those determined by               
          respondent for 1995, 1996, 1997, or 1998; (2) whether                       
          petitioners’ gross receipts from the minimart should be increased           
          for 1995 or decreased for 1995, 1996, 1997, or 1998; (3) whether            
          petitioners are liable for an addition to tax pursuant to section           
          6651(a)(1) for 1995, 1996, and 1997; and (4) whether petitioners            
          are liable for a penalty pursuant to section 6662(a) for 1995,              
          1996, 1997, and 1998.                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      



               1  At trial, the parties stipulated or conceded most of the            
          adjustments contained in the notice of deficiency.  The remaining           
          adjustments not addressed by this opinion are computational.                




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