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KERNS v. COMMISSIONER

Docket No. 12728-02.

87 T.C.M. 1082 (2004)

T.C. Memo. 2004-63

Stephen M. and Rebecca A. Kerns v. Commissioner.

United States Tax Court.

Filed March 11, 2004.

Attorney(s) appearing for the Case

Charles Wist and Joan Kehlhof, for the petitioners.

John D. Faucher, for the respondent.

MEMORANDUM OPINION

COLVIN, Judge:

Respondent determined that petitioners are liable for deficiencies in Federal income tax of $3,357 for 1998 and $3,637 for 1999, and accuracy-related penalties under section 6662(a) of $671 for 1998 and $727 for 1999.

After concessions, the sole issue for decision is whether a $7,800 payment by petitioner Stephen M. Kerns's wholly owned corporation in 1999 for a permanent seat license allowing him to buy six season...

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