- 2 - section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: Respondent determined a deficiency in petitioner Angela Matthews' 1991 Federal income tax in the amount of $8,362 and an addition to tax in the amount of $2,091 pursuant to section 6651(a)(1). Respondent also determined a deficiency in petitioner Richard Matthews' 1991 Federal income tax in the amount of $9,597 and an addition to tax in the amount of $2,399 pursuant to section 6651(a)(1). Upon motion by the parties, these two dockets were consolidated for trial, briefing, and opinion. In her Amendment to Answer in each docket, respondent asserted an increased deficiency and addition to tax. Thus, the amounts of the deficiencies and additions to tax in issue for 1991 are as follows: Docket No. 16603-94--Angela Matthews Deficiency Sec. 6651(a)(1) Addition to Tax $23,255 $5,814 Docket No. 16604-94--Richard L. Matthews Deficiency Sec. 6651(a)(1) Addition to Tax $41,316 $10,329 1 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011