Eric Jennings - Page 3

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                  The amounts of the deficiencies, additions to tax, and                              
            accuracy-related penalties that were determined by respondent in                          
            the two notices of deficiency are as follows:                                             

             Taxable Year       Deficiency          Addition to        Penalty                        
                                                    Tax                Sec. 6662                      
                                                    Sec. 6651                                         
             1992               $41,489             $8,105             $8,298                         


             1993               47,492              9,590              9,498                          
             1994               54,799              ---                10,960                         

                  The adjustments to income that gave rise to the deficiencies                        
            that were determined by respondent in the two notices of                                  
            deficiency were as follows:                                                               

             Adjustments        1992           1993                    1994                           

             Const. dividends   $111,953            $125,237           $139,462                       
             Rental income      9,447               11,735             16,943                         
             Itemized deducts.    7,297             2,584              3,184                          
             Exemptions         3,772               3,290              2,107                          


                  Respondent issued two notices of deficiency because the                             
            notice for the taxable year 1992 was based on a different filing                          
            status than was the notice for the taxable years 1993 and 1994.                           
            Thus, for the taxable year 1992, respondent determined that                               
            petitioner's filing status was married filing separately, whereas                         





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