- 2 - Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1998 $105,470 –- $21,094 1999 114,603 $27,087.75 22,921 Respondent determined deficiencies, an addition to tax, and penalties with respect to petitioners George R. and Nehad Mansour’s (the Mansours) Federal income taxes for 1996, 1997, 1998, and 1999 as follows: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1996 $93,552 $23,494.20 $18,710.40 1997 18,093 –- 3,618.60 1998 129,324 –- 25,864.80 1999 42,884 –- 8,576.80 The issues for decision in these consolidated cases are: (1) Whether one of petitioners’ S corporations recognized a gain rather than a loss on the sale of its assets; (2) whether petitioners have shown that respondent’s computation of their income for the years in issue using the bank deposits method is inaccurate or that any of the deposits that were made into their personal bank accounts during the years in issue are not taxable; (3) whether petitioners are liable for additions to tax under section 6651(a)(1); and (4) whether petitioners are liable for accuracy-related penalties under section 6662(a). 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 andPage: 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