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$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.
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