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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 and
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Last modified: May 25, 2011