William H. Mansel, Jr. and Angela W. Mansel - Page 3

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          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      
               Respondent determined a deficiency of $5,051 in petitioners’           
          Federal income tax and the accuracy-related penalty under section           
          6662(a) in the amount of $1,010 for 2001.                                   
               After concessions by respondent, the issues for decision               
          are:  (1) Whether William H. Mansel, Jr. (petitioner) realized              
          income in the receipt of $13,500 in commission payments from an             
          automobile dealership during 2001, and (2) whether petitioners              
          are liable for the accuracy-related penalty under section                   
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are made a part hereof.                  
          Petitioners’ legal residence at the time the petition was filed             
          was Pelham, Alabama.                                                        
               Petitioner was an office finance manager for a car                     
          dealership located at Prattville, Alabama.  His income from that            
          activity consisted of commissions from sales of motor vehicles              
          based on a percentage of what he referred to as “front-end                  
          profits” and a percentage of what he also referred to as “back-             

               2At trial, respondent conceded two adjustments in the notice           
          of deficiency:  A $1,028 income determination for the refund of             
          State income taxes and a $704 interest income adjustment from               
          Arcadia, a financial institution.  Another concession was made by           
          respondent during the trial relating to the commissions, and that           
          concession is addressed in the consideration of that issue.                 

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