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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.
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Last modified: May 25, 2011