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Accuracy-Related Penalty
Year Deficiency Under Sec. 6662(a)
1999 $16,654 $3,331.00
2000 32,677 3,517.20
The issues remaining for decision are:
(1) Did petitioners sell certain property on December 2,
1999, for $318,000? We hold that they did.
(2) Did petitioners sell certain property on June 14, 2000,
for $225,000? We hold that they did not.
(3) Are petitioners liable for each of their taxable years
1999 and 2000 for the accuracy-related penalty under section
6662(a)? We hold that they are for 1999 and that they are not
for 2000.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found
except as stated herein.
Petitioners resided in Crownsville, Maryland, at the time
they filed the petition in this case.
In 1981, petitioner Patrick G. O’Malley (Mr. O’Malley)
received a bachelor of science degree in accounting from the
University of Maryland. After graduating from college, Mr.
O’Malley worked for one year for Price Waterhouse. Shortly after
leaving Price Waterhouse, Mr. O’Malley held various jobs in the
food service industry. During 1999 and 2000, the years at issue,
Mr. O’Malley operated various businesses, including a consulting
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