Tibor Guenther Horwath and Christel Horwath - Page 2

                                        - 2 -                                         
               The issues remaining for decision are:                                 
               (1) Are petitioners entitled for each of the taxable years             
          at issue to the depreciation deduction that they claim?  We hold            
          that they are not.                                                          
               (2) Are petitioners entitled for the taxable year 1998 to a            
          deduction of $14,686 for travel expenses?  We hold that they are            
          not.                                                                        
               (3) Are petitioners liable for each of the taxable years at            
          issue for the accuracy-related penalty under section 6662(a)1?              
          We hold that they are.                                                      
                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated and are so found.               
               Petitioners resided in Falmouth, Virginia, at the time they            
          filed the petition in this case.                                            
               In 1988, petitioners formed TG&C Associates, Inc. (TGC), an            
          S corporation, that at all relevant times provided consulting               
          services to various corporate and government entities.  At all              
          relevant times, TGC’s principal place of business was located in            
          petitioners’ residence.                                                     
               During the taxable years at issue, petitioners were the only           
          two stockholders of TGC.  For each of the taxable years at issue,           
          each petitioner had a zero basis in the TGC stock that each                 

               1All section references are to the Internal Revenue Code               
          (Code) in effect for the years at issue.  All Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           





Page:  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