- 2 - Penalty Year Deficiency I.R.C. Sec. 6663 2000 $106,074 $79,555.50 2001 74,841 56,130.75 2002 74,156 55,617.00 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are: (1) Whether petitioner’s solely owned S corporation received and failed to report taxable income for taxable years 2000, 2001, and 2002; (2) whether petitioners are entitled to reductions in their Federal taxable income for 2000 attributable to additional Employee Embezzlement Account deductions that were not claimed on their return; (3) whether various deductions claimed as business expenses of petitioner’s solely owned corporation should be disallowed as personal expenses of petitioners or for failure to substantiate; (4) whether petitioners are entitled to disallowed deductions relating to their racing activities; and (5) whether petitioners are liable for the fraud penalty pursuant to section 6663 for the years in issue or, in the alternative, whether petitioners are liable for the accuracy- related penalty pursuant to section 6662.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007