- 2 - Federal income taxes for 1995, 1996, and 1997 and penalties under section 6662(a) for those years, respectively, as follows: Year Deficiency Sec. 6662(a) Penalty 1995 $334,589 $66,918 1996 24,739 4,948 1997 158,356 31,671 Respondent determined deficiencies in petitioners Carroll Janis and Donna L. Seldin Janis’s (Carroll and Donna) Federal income taxes for 1995, 1996, and 1997 and penalties under section 6662(a) for those years, respectively, as follows: Year Deficiency Sec. 6662(a) Penalty 1995 $532,930 $106,586 1996 58,635 11,727 1997 169,248 33,849 The issues for decision in these consolidated cases are: (1) Whether petitioners, who inherited an art gallery, can calculate the gallery’s cost of goods sold using the undiscounted value of the gallery’s collection of artwork rather than the discounted value as determined for estate tax purposes and (2) whether petitioners are liable for accuracy-related penalties under section 6662(a) for 1995, 1996, and 1997. 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 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