Frank H. and Marla C. Black - Page 2




                                        - 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.                    





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