- 2 -
Year Deficiency Sec. 6662 Penalty
1995 $119,377 $23,875
1996 68,663 13,733
1997 4,849 970
1998 14,382 12,876
1 Respondent concedes that petitioners are not liable for the accuracy-
related penalty for 1998.
After concessions, we must decide:
1. Whether the notice of deficiency was sent timely. We
hold that it was.
2. Whether petitioners had income in the amounts that
respondent determined for 1995-97. We hold that they did.
3. Whether petitioners had larger costs of goods sold than
respondent determined. We hold that they did not.
4. Whether petitioners may deduct larger amounts for
depreciation and other expenses than respondent determined. We
hold that they may to the extent provided herein.
5. Whether petitioners may deduct soil or water
conservation expenses under section 175.1 We hold that they may
not.
6. Whether petitioners are liable for the accuracy-related
penalty under section 6662 for 1995-97. We hold that they are.
1 Unless otherwise specified, section references are to the
Internal Revenue Code as amended. 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 18 19 20 Next
Last modified: May 25, 2011