- 2 - ers’ Federal income tax (tax), as follows: Accuracy-Related Year Deficiency Penalty 1999 $87,099 $17,420 2000 104,225 20,845 The issues remaining for decision are: (1) Are petitioners entitled for each of the years at issue to deduct gambling losses in excess of the deduction allowed by respondent for each such year? We hold that they are not. (2) Are petitioners liable for each of the years at issue for the accuracy-related penalty under section 6662(a)? We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioners, Terri L. Hartsock (Ms. Hartsock) and Austin W. Hartsock (Mr. Hartsock), resided in Frederick, Maryland, at the time they filed the petition. Around 1994, Mr. Hartsock incorporated his business known as The Frederick Painting Company. Since that time, he and Ms. Hartsock have been employed by that company. During the years at issue, petitioners did not have a mortgage loan with respect to their residence and therefore did not have any mortgage loan expenses. Nor did petitioners have 2(...continued) (Code) in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011