- 2 - Stephen M. Miller, for respondent. HALPERN, Judge: These consolidated cases involve the following determinations by respondent of deficiencies in, additions to, and penalties on petitioners' Federal income tax: Docket No. 21808-93 Michael Ferguson and Valene Ferguson Additions to Tax and Penalties Sec. Sec. Sec. Sec. Year Deficiency 6653 6654 6661 6662 1987 $29,115 -- -- -- $5,823 1988 1,249,580 $36,491 $94,384 $182,456 103,951 1989 117,227 -- -- -- 23,445 1990 75,197 -- -- -- 15,039 1991 66,942 -- -- -- 13,388 Docket No. 18250-94 Roger N. Ferguson and Sybil Ferguson Additions to Tax and Penalties Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(a)(1) 6659 6661 6662(a) 6621(c) 1988 $2,017,297 $170,767$427,524 $163,701 -- 1 1989 160,451 -- -- -- $50,353 -- 1991 624,490 -- -- -- 127,120 -- 1120% of interest due on $1,425,079 Certain adjustments having been agreed to and concessions made, the sole issue remaining for decision is whether petitioners are taxable on the gain in appreciated stock transferred to various charitable organizations under the anticipatory assignment of income doctrine. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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