- 2 - Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE COUVILLION, Special Trial Judge: This matter is before the Court on respondent's motion for entry of decision as to which Richard W. Kochansky (petitioner) has filed an objection. In two notices of deficiency, respondent determined the following deficiencies, additions to tax, and penalties for the years indicated:2 Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a) 6654 6662(b)(1) 1988 $8,115 $2,029 $406 $36 -- 1989 4,035 967 -- -- $807 1990 2,022 -- -- -- 404 At the time the petition was filed, petitioners were legal residents of Idaho. On the date this case was calendared for trial, the parties filed with the Court a written stipulation to be bound (the stipulation). There was no evidence adduced on that date other than the stipulation and the exhibits attached thereto. 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 The deficiencies, additions to tax, and penalty for the years 1988 and 1990 are against Richard W. Kochansky alone. For 1989, the deficiency, addition to tax, and penalty are against Richard W. Kochansky and Monica L. Miller.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011