- 2 - Penalty Year Deficiency I.R.C. sec. 6662 2002 $58,816 $11,763.20 2003 95,217 19,043.40 2004 87,442 17,488.40 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. After concessions by the parties, the sole issue for decision is whether petitioners are liable for the accuracy- related penalties determined by respondent pursuant to section 6662 for substantial understatements of their Federal tax liability for the years in issue. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioners resided in California at the time they filed their petition. For purposes of trial only, this case was consolidated with a related worker classification case at docket No. 12139-06. The amounts of total tax liability that petitioners reported on their income tax returns for the years in issue and the deficiencies determined by respondent, which amounts include disallowed credits, for those years are as follows: Year Tax on return Corrected tax Understatement 2002 $4,499 $61,219* $58,816 2003 5,769 100,326* 95,217 2004 11,566 99,008 87,442 * Includes credits disallowed by respondent for this year.Page: Previous 1 2 3 4 5 NextLast modified: March 27, 2008