- 2 - 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 6662(a).2 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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