- 2 - $575, and $669, for 1996, 1997, 1998, and 1999, respectively. There are four issues for decision. First, were amounts Mr. Namyst (petitioner) received from Intelligent Motion Controls, Inc. (IMC) reimbursements under an accountable plan qualifying under section 1.62-2(c)(2)(i), Income Tax Regs., rather than amounts includable in petitioners’ gross income as compensation? We hold the amounts received were includable in petitioners’ gross income as compensation. Second, were amounts petitioners received for the sale of petitioner’s tools includable in their gross income? We hold that they were. Third, does the 6-year period of limitations under section 6501(e)(1)(A) permit respondent’s determination for 1998? We hold that it does. Fourth, are petitioners liable for the accuracy-related penalty under section 6662(a)? We hold that they are not. FINDINGS OF FACT Some of the facts are stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time the petition was filed, petitioners resided in Eagan, Minnesota. 1(...continued) 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
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