- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008