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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
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.
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