United States Second Circuit

In a consolidated appeal, the orders and decisions of the United States Tax Court finding deficiencies in petitioners' income tax payments and assessing accuracy-related penalties under 26 U.S.C. section 6662, is affirmed where: 1) the Tax Court did not clearly err in finding that the contributions by petitioners' business entities to the life insurance plans were not ordinary and necessary business expenses, as the evidence shows that the contributions were made solely for the personal benefit of petitioners; 2) the Tax Court's treatment of one of the business entities' contributions was not improper; and 3) the Tax Court did not clearly err in finding that petitioners were "negligent" and acted in "disregard" of the tax rules and regulations in imposing the accuracy-related penalties.

Appellate Information

• Decided 08/09/2012
• Published 08/09/2012

Judges

• Chin

Court

• United States Second Circuit

Counsel