§66621

Allen’s federal income tax and accuracy- Served 07/11/23 2 [*2] related penalties pursuant to section 66621 for the 2005 and 2006 taxable years as follows: Year Deficiency § 6662 Penalty 2005 $2,646,969 $529,394 2006 2,054,073 410,815 By a notice of final partnership administrative adjustment (FPAA) dated September 28, 2015, the IRS adjusted Humbolt Investments, LLC’s (Humbolt) ordinary income for the 20

We hold that he did, except for those concerning certain depreciation expenses; (2) whether the Slaters received constructive dividends from Austin Otology in taxable years 2007, 2008, and 2009.

MEMORANDUM OPINION WELLS, Judge: Respondent determined a deficiency in petitioner's 2003 Federal income tax of$1,456 and a deficiency in petitioner's 2004 Federal income SERVED JUL 23707 - 2 - tax of$22,446 and an accuracy-relatedpenalty pursuant to section 66621 of $4,489.20.

We hold that only 600 shares should be included in the estate.

We hold that it was not because Burndy-US did not own more than 50 percent of the voting power of Burndy-Japan stock or more than 50 percent of the value of Burndy-Japan stock in 1992.

OPINION WELLS, Judge: Respondent determined deficiencies in petitioners' income taxes of $60,371, $14,884, $6,875, and $20,173 for their 1988, 1991, 1992, and 1993 taxable years respectively, and additions to tax pursuant to section 66621 of $2,977, $1,375, and $4,035 for their 1991, 1992, and 1993 taxable years respectively.

MEMORANDUM OPINION KROUPA, Judge : Respondent determined a $23,027 deficiency in petitioner' s Federal income tax and a $2,106 .80 accuracy- related penalty under section 66621 for 2004 .

MEMORANDUM OPINION VASQUEZ, Judge: Respondent determined a $2,987 deficiency in and a $327.40 penalty pursuant to section 66621 on petitioner’s 1999 Federal income tax.

1988 Protocol . . . . . . . . . . . . . . . 64 4. Conclusion . . . . . . . . . . . . . . . . . 67 COLVIN, Judge: Respondent determined deficiencies in petitioners’ income and withholding taxes and a penalty as follows: - 4 - Withholding Income tax Sec. 66621 tax Year deficiency penalty deficiency 1991 $1,733,207 $380,298 1992 753,456 256,626 1993 24,892,344 4,978,469 $2,700,316 1 Unless otherwise specified, section references are to the Internal Revenue Code in effect in the years in issue, and

Background In a statutory notice of deficiency dated April 29, 1998, respondent determined a deficiency in petitioner’s Federal income tax for the year 1995 in the amount of $9,076, and a penalty pursuant to section 66621 in the amount of $640.

Held, further, under the facts of this case, R abused his discretion in determining that P must use the accrual method of accounting to report its income for Federal income tax purposes. Kevin P. Courtney, for petitioner. Steven Walker, for respondent. PARR, Judge:* Respondent determined an $82,577 income tax deficiency for petitioner's tax year ended August 31, 1994, and a section 66621 accuracy-related penalty of $16,515. The issues for determination are: (1) Whether the material provided by p

Respondent determined a deficiency of $216,042 in petitioner's 1994 Federal income tax and an accuracy-related - 2 - penalty under section 66621 in the amount of $43,208.

MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ending - 2 - September 30, 1990, of $98,314, and an accuracy-related penalty under section 66621 of $24,851.

The Commissioner also determined that Seabrook is Served 01/21/25 2 [*2] subject to an accuracy-related penalty under section 66621 and a reportable transaction penalty under section 6662A.

Respondent issued a Notice of Deficiency that determined the settlement amount was includible in her 2019 gross income and that she was liable for an income tax deficiency of $28,354, and a section 66621 penalty of $5,671.

MEMORANDUM FINDINGS OF FACT AND OPINION WAY, Judge: Respondent issued a separate Notice of Deficiency to each petitioner in these consolidated cases determining deficiencies in petitioners’ 2015 and 2016 federal income tax and imposing section 66621 accuracy-related penalties.

In a Notice of Deficiency dated November 13, 2017, respondent determined that the farming activity at Pecandarosa Ranch was not an activity engaged in for profit within the meaning of section 183 and disallowed deductions attributable to it that the Youngs claimed for the years at issue.

Spiezio’s (collectively, Spiezios) 2015 joint federal income tax of $147,807 and an accuracy-related penalty under section 66621 of $29,561.

notice of deficiency dated April 12, 2018, in which the Internal Revenue Service (IRS or respondent) determined income tax deficiencies for taxable years 2003, 2004, 2005, 2006, 2007, 2008, 2009, and 2011 (years at issue) of $20,088, $5,078, $6,136, $23,011, $10,785, $15,910, $28,130, and $95,994, respectively, and accuracy-related penalties under section 66621 of $4,018, $1,016, $1,227, $4,602, $2,157, $3,182, $5,626, and $19,199, respectively.

The issues for decision are (1) whether ES NPA underreported its income for the 2011 tax year and (2) whether an accuracy-related penalty under section 66621 is appropriate.

MEMORANDUM FINDINGS OF FACT AND OPINION GREAVES, Judge: Respondent determined deficiencies in, and section 66621 accuracy-related penalties with respect to, Clary Hood, Inc.’s (petitioner or 1 Unless otherwise noted, all section references are to the Internal Revenue Code in effect at all relevant times, all dollar amounts are rounded to the nearest Served 03/02/22 - 2 - [*2] company) Federal income tax for its tax years ending May 31, 2015 and

MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined federal income tax deficiencies of $13,886 and $10,079 and section 66621 accuracy-related penalties of $2,656 and $2,016 for taxable years 2013 and 2014 (years in issue), respectively.

MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined for tax year 2008 a deficiency in tax of $44,056 and a section 66621 penalty of $8,811, and for tax year 2009 a deficiency in tax of $28,541 and a section 6662 penalty of $5,708.

Evans and Donna Evans (petitioners) for SERVED JAN 2 0 2015 - 2 - [*2] the taxable years 2009 and 2010, deficiencies and accuracy-relatedpenalties under section 66621 in the following amounts: Penalty Year Deficiency sec.

Evans and Donna Evans (petitioners) for SERVED JAN 2 0 2015 - 2 - [*2] the taxable years 2009 and 2010, deficiencies and accuracy-relatedpenalties under section 66621 in the following amounts: Penalty Year Deficiency sec.

MEMORANDUM FINDINGS OF FACT AND OPINION KROUPA, Judge: Respondent deteñnined deficiencies exceeding $1.1 million and section 66621 accuracy-relatedpenalties regarding petitioner's Federal 1All section reference(cid:0)54a1re to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the.Tax Court Rules ofPractice and Procedure, unless otherwise indicated.

SERVED FEB 1 1 2013 -2- In a notice ofdeficiency dated September 19, 2011, respondent determined a deficiency in petitioners' 2009 Federal income tax of$18,420 and a section 66621 accuracy-relatedpenalty of$3,684.

Respondent also determined penalties under section 66621 of $17,163 and $3,422 for 2005 and 2006, respectively.

Respondent also determined penalties under section 66621 of $193,231, $369,700, and $243,582 for 2002, 2003, and 2004, respectively, as well as an addition to tax under section 6551(a) (1) of $42,742.for 2002.

(Ironbridge Corp.) on July 24, 2007, which determined deficiencies and section 66621 accuracy-relatedpenalties for 2001 and 2002.

Respondent also determined section 66621 accuracy-related penalties of$1,086.60, $2,015.20, and $826.60 for 2005, 2006, and 2007, respectively.

(Ironbridge Corp.) on July 24, 2007, which determined deficiencies and section 66621 accuracy-relatedpenalties for 2001 and 2002.

Respondent also determined penalties under section 66621 of $193,231, $369,700, and $243,582 for 2002, 2003, and 2004, respectively, as well as an addition to tax under section 6551(a) (1) of $42,742.for 2002.

petitioner overstated the amount shown for returns and allowances on the Schedule C, Profit or Loss From Business, included with her Federal income tax return for that year; (3) whether petitioner is entitled to deductions for interest expenses not claimed on her 2005 or 2006 Federal income tax return; and (4) whether petitioner is liable for the section 66621 accuracy-related penalty for either of.

(1) Whether Hist oric Boardwalk Hall is a shain; (2) whether Pitney Bowes was a partner in Historic Boardwalk Hall; 3) whether New Jersey Sports and, Exposition Aut hority (NJSE or petitioner) transferred the benefits and burdens of ownership of the East Hall to liistoric Boardwalk Hall and - 3 - (4) whether Historic Boardwalk Hall is liable for section 66621 accuracy-related penalties for years 2000, 2001, and 2002.

rporation, Knutsen-Rowell, Inc. (Knutsen), for 2001 and 2002. Respondent determined the following deficiencies, additions to tax, and penalties:2 Knutsen, docket No. 27626-07 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a) (1) Sec. 66621 2001 $67,973 $6,797 $13,595 2002 14,957 -0- 2,991 Respondent asserts in the answer that Knutsen is liable for the fraud penalty under sec. 6663 for 2001 and 2002 and if not, for the accuracy-related penalty under sec. 6662. PLC, docket No.

MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: The sole issue for decision in these deficiency cases is whether petitioners are liable for the accuracy-related penalty under section 66621 in the following amounts: All section references are to the Internal Revenue Code.

MEMORANDUM FINDINGS OF FACT AND OPINION M RVEL, Judge: Respondent determined a Federal income tax defici ncy of $6, 941 and a section 66621 accuracy-related penalty of $1,Š88 with respect to petitioner's 2005 takable year and 11 section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the' Tax CoÜrt Rules oÏ Practice ard Procedure.

In separate notices of deficiency issued to petitioners, respondent determined that (1) Holdner Farms was a partnership (or a joint venture taxed as a partnership) for Federal income tax purposes in 2004-2006, (2) petitioners were equal partners in the partnership, and (3) William Holdner was liable for the section 66621 accuracy-related penalty for 2004-2006 .

MEMORANDUM OPINION KROUPA, Judge : Respondent determined an $8,700 deficiency in petitioners' Federal income tax and a $1,740 accuracy-related penalty under section 66621 for 2004 .

MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge : On September 14, 2006, respondent mailed to petitioners a notice of deficiency (notice) that determined deficiencies in their Federal income tax of $140,135 and $154,888 for tax years 2002 and 2003, respectively, and penalties unde r SERVED Apr 14 2010 2 - section 66621 of $28,027 and $30,978 for 2002 and 2003, respectively .

RUWE, Jude : Respondent determined a $30,911 deficiency, $6,583 addition to tax under section 6651 .(a)(1)' for failure t o timely file, .and a $6,182 .20-,accuracy-related penalty unde r section 66621.(a)-,in tax .

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge : Respondent determined deficiencies of $5,074 and $7,396 in petitioner's 2002 and 2003 Federal income taxes and accuracy-related penalties under section 66621 of $1,015 an d 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue,'and all Rule references are to the Tax Court Rules of Practice an d (continued.

6662(a) 2004 $12,656 $2,531 2005 8,835 1,767 SERVED SEP 14 2009 t - 2 - The issues for decision are : (1) Whether, petitioner is entitled to claimed medical expense deductions in 2004 and 2005 in amounts greater than those allowed by respondent ; and (2) whether petitioner is liable for the section 66621'accuracy- --rela(cid:127)ted- ..penalty for 2004 and 2005 .

Respondent also determined that a,section 66621 accuracy-related penalty applies .

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: Respondent determined a deficiency of $309,382 and a section 66621 accuracy-related penalty of $61,876.40 with respect to petitioner’s 1999 Federal income tax.

MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge : Respondent determined a deficiency of $7,239 in petitioner's Federal tax for 2002, as well as a penalty of $1,447 .80 under section 66621, and additions to tax of $325 .7 6 'Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Respondent also determined a $54,880 -2- accuracy-related penalty under section 66621 for 1999 and a $63,548 penalty for 2000.

- 2 - OPINION VASQUEZ, Judge: Respondent determined an $8,066 deficiency in petitioner’s 2001 Federal income tax and a $1,613.20 section 66621 penalty.

- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: Respondent determined a deficiency of $46,666 and an accuracy-related penalty under section 66621 of $9,333.20 in petitioners Alan D.

- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: Respondent determined a deficiency of $46,666 and an accuracy-related penalty under section 66621 of $9,333.20 in petitioners Alan D.

MEMORANDUM OPINION CHABOT, Judge: Respondent determined deficiencies in individual income tax and penalties under section 66621 (accuracy-related) against petitioner as follows: Penalties Year Deficiency Sec.

In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income - 2 - tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows: Waterfall Farms, Inc., Docket No.

In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income - 2 - tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows: Ricky & Suzetta Schmidt, Docket No.

In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income - 2 - tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows: Ronald & Suzanne Weeldreyer, Docket No.

In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income - 2 - tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows: Robert W.

oss From Business, nonemployee compensation of $26,738; (2) whether petitioner is entitled to claim Schedule C automobile expenses of $8,910; (3) whether he is entitled to - 2 - claim Schedule C office expenses of $3,600; (4) whether he is subject to self-employment tax of $6,365; and (5) whether he is liable for an accuracy-related penalty under section 66621 of $1,052.2 FINDINGS OF FACT Some of the facts have been stipulated and are so found.

In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income - 2 - tax and accuracy-related penalties under section 66621 for 1995, 1996, and 1997 as follows: Waterfall Farms, Inc., Docket No.

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: Respondent determined deficiencies of $5,250 and $2,520, and section 66621 penalties of $1,050 and $504, with respect to petitioner’s 1993 and 1994 Federal income taxes, respectively.

MEMORANDUM OPINION GERBER, Judge: Respondent determined a deficiency of $873,544 and a penalty under section 66621 of $168,999 in the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the date of decedent’s death, and all Rule references are to the Tax Court Rules of Practice and Procedure.

MEMORANDUM OPINION GERBER, Judge: Respondent determined deficiencies in petitioner’s Federal income tax and section 66621 accuracy- related penalties as follows: 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable periods under consideration, and all Rule references are to the Tax Court Rules of Practice and Procedure.

MEMORANDUM OPINION DEAN, Special Trial Judge: Respondent determined deficiencies in Federal income tax, and accuracy-related penalties under section 66621 for petitioner Darlene Esposito as follows: 1All section references are to the Internal Revenue Code in effect for the years at issue.

respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: Respondent determined deficiencies in petitioners’ Federal income taxes and penalties as follows: - 2 - James P. Shea and Patricia H. Shea, docket No. 2860-96 Penalty Year Deficiency Sec. 66621 1992 $244,224 $48,485 Christopher M. and Kim A. Shea, docket No. 2861-96 Penalty Year Deficiency Sec. 6662 1992 $47,945 $9,589 Because these cases present common questions of fact and law, they were consolidated for purposes of trial, brief

MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined deficiencies in petitioner’s Federal income tax and accuracy-related penalties under section 66621 for the 1991, 1992, and 1993 taxable years as follows: 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable years under consideration.

Blaine C. Holiday, for respondent. MEMORANDUM OPINION MARVEL, Judge: Respondent determined the following deficiencies and accuracy-related penalties with respect to petitioner’s Federal income taxes: - 2 - Accuracy-related Year Deficiency penalty - sec. 66621 1992 $4,053 $811 1993 3,612 722 1994 4,732 946 After concessions, discussed infra, the issues for decision are: (1) Whether petitioner may deduct business expenses claimed in connection with his trucking/hauling business in excess of those

respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: Respondent determined deficiencies in petitioners’ Federal income taxes and penalties as follows: - 2 - James P. Shea and Patricia H. Shea, docket No. 2860-96 Penalty Year Deficiency Sec. 66621 1992 $244,224 $48,485 Christopher M. and Kim A. Shea, docket No. 2861-96 Penalty Year Deficiency Sec. 6662 1992 $47,945 $9,589 Because these cases present common questions of fact and law, they were consolidated for purposes of trial, brief

GERBER, Judge: Respondent determined deficiencies in petitioners' Federal income tax and a section 66621 accuracy- related penalty as follows: Year Deficiency Sec.

- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined a deficiency in the Federal income tax of decedent Hilda Ashman for the taxable year 1993 of $54,542 and a section 66621 accuracy-related penalty of $10,908.

MEMORANDUM OPINION RUWE, Judge: Respondent determined a deficiency of $1,225,296 in petitioner's Federal estate tax plus an accuracy- related penalty under section 66621 in the amount of $202,811.

MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined a deficiency in petitioner's 1990 Federal income tax of $1,376,520, and a penalty under section 66621 of $275,304.

MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined a $189,212 income tax deficiency and a $37,842 penalty under section 66621 for 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the period under consideration.

ter, for petitioner. William L. Blagg, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined deficiencies in petitioner's Federal income tax and accuracy-related penalties as follows: 2 Penalty Year Deficiency Sec. 66621 1990 $433,706 $86,741 1991 9,741 1,948 1992 4,354 871 1 Respondent concedes that petitioner is not liable for the accuracy- related penalty. Petitioner was the sole shareholder of Eagle's Nest Homes, Inc. (Eagle), an S corporation which sol

MEMORANDUM FINDINGS OF FACT AND OPINION TANNENWALD, Judge: Respondent determined a deficiency in petitioners' Federal income tax in the amount of $92,790.92 and a - 2 - penalty under section 66621 in the amount of $18,558.00 for the taxable year 1990.

MEMORANDUM FINDINGS OF FACT AND OPINION SCOTT, Judge: Respondent determined a deficiency in petitioner's Federal income taxes for the calendar year 1990 in the amount of $14,432, and an accuracy-related penalty under section 66621 in the amount of $2,886.

MEMORANDUM OPINION PARR, Judge: Respondent determined a deficiency in petitioner's Federal income tax for 1989 in the amount of $20,400, and a penalty under section 66621 in the amount of $4,080.

of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision: (1) Whether petitioner is entitled to a deduction as a trade or business expense of the cost of purchasing tires which it contends were for use on leased trucks; and (2) whether petitioner is liable for an accuracy- related penalty under section 66621 as determined by respondent.

h, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SCOTT, Judge: Respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties for the calendar years 1990 and 1991 as follows: Penalty Year Deficiency Sec. 66621 1990 $6,300 $1,260 1991 8,668 1,734 The issues for decision are whether petitioners are entitled to deductions for alimony pursuant to sections 71 and 215 in the amounts of $30,000 in 1990 and $10,000 in 1991,2 and whether petitioners are l