Steven J. and Terry L. Namyst - Page 2

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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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