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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.
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Last modified: May 25, 2011