- 2 - penalty under section 6662(a)1 of $2,965.80 for 2000 and $8,152.20 for 2001. The issues for decision are: 1. Whether petitioners are entitled to more itemized deductions than respondent allowed. We hold that they are not. 2. Whether petitioners may claim net operating losses (NOLs) of $183,455 for 2000 and $110,367 for 2001. We hold that they may not. 3. Whether petitioners may deduct partnership losses of $32,065 claimed on Schedule E, Supplemental Income and Loss, for 2001. We hold that they may not. 4. Whether petitioners are liable for the accuracy-related penalty under section 6662(a) for 2000 and 2001. We hold that they are. 5. Whether petitioners are liable for a penalty under section 6673 for instituting proceedings primarily for delay and for maintaining frivolous or groundless positions. We hold that they are not. Computational adjustments will be required to resolve the taxable amounts of petitioners’ Social Security benefits in 2000, the amounts of petitioners’ standard deductions for 2000 and 2001, and the amounts of petitioners’ exemptions for 2001. 1 Section references are to the Internal Revenue Code in effect for the taxable years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011