Kamil F. and Nagwa Gowni - Page 2

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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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