- 3 - (6) whether petitioner is liable for additions to tax under section 6651(a)(1) for tax years 1998, 1999, and 2000. We hold that he is. (7) whether petitioner is liable for accuracy-related penalties under section 6662(a) for disallowed deductions. We hold that he is not liable for those penalties in 1998 and 1999. Background Petitioner was a resident of Prospect, Kentucky, at the time he filed his petition. Petitioner was the former president and chief executive officer (CEO) of the Allegheny Health Education & Research Foundation (AHERF), a Pennsylvania corporation. AHERF terminated petitioner in June 1998 and filed chapter 11 bankruptcy proceedings 1 month later in July of that year. A. 1998 Charitable Deduction In 1990, petitioner sold his home to a subsidiary of AHERF, Jellico, Inc. (Jellico). In 1992, petitioner signed a land installment contract with Jellico to repurchase the home for $1,280,000 with payment spread over 20 years. The terms of this contract required petitioner to pay 5 percent of the principal ($64,000) each April 30th and interest payments of 7.5 percent on the remaining principal each October 30th. The contract also required petitioner to pay all taxes due on the residence. Jellico retained title during the contract period and would transfer title when petitioner paid the full contract price. IfPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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