Angela Matthews - Page 2

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            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.                                                                                




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