- 2 - Respondent determined a deficiency of $6,532 in petitioner’s Federal income tax for 2001, a section 6651(a)(1) addition to tax of $1,568, and a section 6662(a) accuracy-related penalty of $1,306. Following concessions, the issues for decision are: (1) Whether petitioner received unreported income as a shareholder in an S corporation, as reported on Schedule K-1; (2) whether petitioner received capital gain income from the sale of his shares in an S corporation; (3) whether petitioner is liable for an addition to tax under section 6651(a)(1); and (4) whether petitioner is liable for an accuracy-related penalty under section 6662. Background Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated by this reference. At the time of filing the petition, petitioner resided in Cape Coral, Florida. Petitioner and Rolan Taylor (Mr. Taylor) were each 50- percent shareholders in Edgington, Mullins, & Taylor Funeral Home, Inc. (Edgington Mullins), an S corporation doing business in Winchester, Kentucky. Petitioner was also employed by Edgington Mullins as an embalmer. Petitioner purchased his one-half interest in Edgington Mullins from Betty Edgington for approximately $35,000 in 1998. Petitioner’s business relationship with Mr. Taylor deteriorated,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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