Dennis E. Runkle and Debra A. Runkle - Page 2

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          failure to file a timely income tax return and alternatively                
          under section 6651(a)(1) for failure to file timely.  Respondent            
          also determined that petitioners were liable for the years at               
          issue for the penalty under section 6654 for failure to pay                 
          estimated taxes.  After concessions, the issues to be decided               
          include whether petitioners are liable for the addition to tax              
          under section 6651(f) for fraudulent failure to file a timely               
          income tax return.  We hold that petitioners are liable.  We                
          therefore do not need to decide alternatively whether petitioners           
          are liable for the addition to tax under section 6651(a)(1).                
               The second question we are asked to decide is whether                  
          petitioner Dennis E. Runkle (Mr. Runkle) is entitled to deduct              
          business expenses in excess of the 19.2-percent deduction ratio             
          of expenses to income that respondent allowed in the notice of              
          deficiency (deficiency notice), dated August 7, 2002, based upon            
          the expenses Mr. Runkle claimed regarding his insurance-related             
          business on the 3 previous years’ tax returns.  We hold that he             
          is not.                                                                     
               The third issue is whether petitioners are liable for the              
          years at issue for the addition under section 6654 for failure to           
          pay estimated taxes.  We hold that petitioners are liable.                  



               1(...continued)                                                        
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  




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