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1999 the following deficiency in, and accuracy-related penalty
under section 6662(a)2 on, the Federal income tax (tax) of peti-
tioners in each of these consolidated cases:
Accuracy-Related
Petitioners Deficiency Penalty
Howard J. Kaplan and $252,728 $91,714
Brenda L. Kaplan
Matthew B. Marceron and 18,169 6,839
Sherry R. Marceron
Dean A. Caldwell and 137,931 49,736
Cathy M. Caldwell
The issues remaining for decision are:
(1) Are petitioners in each of these cases entitled for
1999 to a deduction under section 170(a) for a claimed noncash
charitable contribution? We hold that they are not.
(2) Are petitioners in each of these cases liable for 1999
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.
At the time they filed their respective petitions, Howard J.
Kaplan (Mr. Kaplan) and Brenda L. Kaplan (Ms. Kaplan) resided in
Winston-Salem, North Carolina, Matthew B. Marceron (Mr. Marceron)
and Sherry R. Marceron (Ms. Marceron) resided in Clemmons, North
Carolina, and Dean A. Caldwell (Mr. Caldwell) and Cathy M.
2All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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