- 2 - of $53,532 with regard to petitioners William and Josephine Houchin’s 1999 Federal income tax. Respondent determined the following deficiencies in and accuracy-related penalties on petitioner W.C. Houchin Corp.’s Federal income taxes: Penalty Year Deficiency Sec. 6662(a) 1998 $1,211,643 $242,329 1999 1,276,748 255,350 After concessions,3 we must decide (1) whether petitioner W.C. Houchin Corp. should recognize $6,145,315 of lawsuit settlement proceeds in income in 1998, (2) whether petitioners William and Josephine Houchin are liable for the accuracy-related penalty pursuant to section 6662(a) for 1999, and (3) whether W.C. Houchin Corp. is liable for the accuracy-related penalty pursuant to section 6662(a) for 1998. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners William and 2(...continued) the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure. 3 On brief, respondent conceded the 1999 deficiency and penalty related to W.C. Houchin Corp. Petitioners and respondent stipulated the treatment of several adjustments in the notices of deficiency issued to W.C. Houchin Corp. for the year 1998 and to William and Josephine Houchin for the year 1999 if the Court finds for respondent with regard to the recognition of income by W.C. Houchin Corp. in 1998.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