- 13 - could result in the imposition of an accuracy-related penalty under section 6662. After receiving the prefiling notice, petitioner visited Barnes at Elk Grove Ranch. Barnes told petitioner that the letter was a part of an “ongoing bitter battle” and that Hoyt was still an enrolled agent. Barnes took petitioner on a tour of Elk Grove and the Laguna office and showed him a copy of the Bales case and other documents. On February 24, 1997, respondent sent petitioner a letter indicating that petitioner’s 1994 and 1995 tax years were under examination. On May 3, 2001, respondent sent petitioner a notice of deficiency. Respondent disallowed all of petitioner’s Schedule F deductions for 1994 and 1995 and determined that the “Farm income, sales of livestock” listed on the Schedules F were not includable in income.6 As a result, respondent determined deficiencies in petitioner’s Federal income taxes of $11,106 and $17,410 for 1994 and 1995, respectively. Respondent further determined that the underpayments of tax were attributable to gross valuation misstatements, and therefore petitioner was liable for 40-percent accuracy-related penalties under section 6662(h) of $4,442 and $6,932, respectively. 6 Petitioner has conceded that he did not receive farm income and is not entitled to any Schedule F deductions for 1994 and 1995. See supra note 2.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011