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Frank H. Black
Year Deficiency Penalty sec. 6662(a) Penalty sec. 6663
1991 $22,904 n/a $17,178.00
1992 60,262 n/a 45,196.50
Marla C. Black
Year Deficiency Penalty sec. 6662(a) Penalty sec. 6663
1991 $22,904 $4,580.80 n/a
1992 60,262 12,052.40 n/a
After concessions, the issues we must decide are: (1)
Whether petitioner Frank Black is liable for the fraud penalty
pursuant to section 66631 for taxable years 1991 and 1992; (2)
whether assessment of the deficiencies in income tax and
penalties for the taxable years 1991 and 1992 is barred by the
statute of limitations; (3) whether petitioners failed to report
income of $107,082 and $160,706, respectively, on their 1991 and
1992 joint income tax returns; (4) whether petitioners have
substantiated the existence or amounts of any net operating
losses for the taxable years 1991 and 1992; (5) whether
petitioners have substantiated that they are entitled to capital
loss carryover deductions for the taxable years 1991 and 1992 of
$3,000 for each year; (6) whether petitioners failed to report
interest and dividend income on their 1992 joint return of $3,748
and $35, respectively; and (7) whether petitioner Marla Black is
liable for a penalty pursuant to section 6662(a).
1Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code, as amended.
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Last modified: March 27, 2008