- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011