- 2 - $21,059.20. After concessions,2 the issues presented for our consideration are: (1) Whether petitioners’ income was understated and (2) whether petitioners are subject to section 6662(a) penalties for substantial understatement of tax or negligent disregard of the rules or regulations. FINDINGS OF FACT3 Petitioners Nick Kikalos and Helen Kikalos resided in Hammond, Indiana, at the time their petition was filed. In the statutory notice of deficiency, respondent determined that petitioners had unreported income from the following sources: (1) Coupon and buy-down reimbursement payments from tobacco companies; (2) rack and promotional payments; (3) vendor refunds and reimbursements; and (4) insurance recovery payments. During 1997, Nick Kikalos4 (petitioner) owned and operated four retail stores under the name of Nick’s Liquor Mart (Nick’s Liquors) in Hammond, Indiana, selling cigarettes, beer, liquor, wine, and other products. During the year at issue, cigarette manufacturers employed “buy-down” programs to lower the cost of cigarettes at which retailers, including Nick’s Liquors, sold to 2 Respondent conceded $23,244 of the $224,620 gross receipts adjustment, as well as an adjustment of $19,652 with respect to unreported income from H&L Display Co. 3 The parties’ stipulation of facts is incorporated by this reference. 4 Petitioner Helen Kikalos is a party to this case by reason of the fact that she filed a joint Federal income tax return with Nick Kikalos for the year under consideration.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