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all Rule references are to the Tax Court Rules of Practice and
Procedure. After concessions, the issues for decision are:
(1) Whether petitioners have unreported flowthrough income
for 1997 resulting from overstated cost of goods sold on the
Federal income tax return for petitioner Timothy Kosinski’s
solely owned S corporation;
(2) whether petitioners are liable for the fraud penalty
pursuant to section 6663 for the year in issue, or, in the
alternative, whether petitioners are liable for the accuracy-
related penalty pursuant to section 6662;
(3) whether petitioner Barbara Kosinski is entitled to
relief pursuant to section 6015 for 1997; and
(4) whether the statute of limitations bars assessment and
collection of petitioners’ income tax liabilities for 1997.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated into our findings by this reference.
Petitioners are married and resided in Novi, Michigan, at the
time that they filed their petition.
Petitioner Timothy Kosinski (petitioner) has been a licensed
dentist since 1984 and was employed as an associate in a dental
practice until 1991. In 1992, petitioner incorporated Timothy F.
Kosinksi, P.C., his solely owned corporation, and was practicing
dentistry under this name in 1997.
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