- 2 - Donald W. MacPherson and Bradley Scott MacPherson, for petitioners. Jonae A. Harrison and J. Robert Cuatto, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: In these consolidated cases, respondent determined the following deficiencies and penalties with respect to petitioners’ Federal income taxes: Penalty Year Deficiency Sec. 6662, I.R.C. 1996 $1,364,714 $272,942.80 1997 2,348,943 608,473.00 1998 1,108,775 221,755.00 After concessions by the parties, the principal issues for decision are: (1) Whether petitioners are entitled to deductions claimed through and in connection with expenditures of two related S corporations, Mayor Pharmaceutical Laboratories, Inc. (Mayor), and KareMor International, Inc. (KareMor), for the taxable years 1996, 1997, and 1998; (2) whether petitioners are entitled to include in the cost of goods sold for Mayor an amount claimed for purchases in 1998; (3) whether petitioners are entitled to a reduction in adjusted gross income of $550,000 for the taxable year 1996; andPage: 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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