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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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Last modified: May 25, 2011