James J. McCarron III and Michelle McCarron - Page 3

                                        - 2 -                                         
               Respondent determined deficiencies in petitioners' Federal             
          income taxes, additions to tax for failure to file, and accuracy-           
          related penalties as follows:                                               
                                        Addition to Tax     Penalty                   
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)              
               1993      $16,305        $3,668.63           $3,261.00                 
               1994      13,875         3,492.30            2,775.00                  
               1995      11,689              -0-       2,337.80                       

               The issues for decision are:1  (l) Whether petitioners                 
          received unreported income during 1993, 1994, and 1995; (2)                 
          whether petitioners are entitled to deductions on Schedule A,               
          Itemized Deductions, and deductions on Schedule C, Profit or Loss           
          From Business, for 1993, 1994, and 1995 in excess of those                  
          allowed by respondent; (3) whether petitioners are entitled to              
          earned income credits for 1993, 1994, and 1995; (4) whether                 
          petitioners are liable for additions to tax for 1993 and 1994 for           
          failure to file timely returns; and (5) whether petitioners are             
          liable for accuracy-related penalties for 1993, 1994, and 1995.             
                                     Background                                       
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  Petitioners                 
          resided in Silver Spring, Maryland, at the time the petition was            
          filed.                                                                      


               1The amounts of any liabilities for and deductions of self-            
          employment taxes depend on the resolution of the other issues in            
          this case.                                                                  




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