Stephen P. and Sharon L. Sherwood - Page 2

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               Respondent determined deficiencies in petitioners' Federal             
          income taxes, additions to tax, and penalties for the years 1991,           
          1992, and 1993 as follows:                                                  
          Petitioner husband:                                                         
                                   Additions to Tax              Penalty              
          Year   Deficiency   Sec. 6651(a)(1)   Sec. 6651(f)   Sec. 6663(a)           
          1991     $4,718          $100           --             $3,538               
          1992      5,419          --             $430           --                   
          1993      4,707          --             124            --                   
          Petitioner wife:                                                            
                                   Additions to Tax              Penalty              
          Year   Deficiency   Sec. 6651(a)(1)   Sec. 6651(f)   Sec. 6663(a)           
          1991     $4,713          $100           --             $3,535               
          1992      5,394          --             $411           --                   
          1993      4,707          --             124            --                   
               The issues for decision are: (1) Whether petitioners failed            
          to report income in amounts determined by respondent for the                
          years 1991, 1992, and 1993; (2) whether petitioners are liable              
          for the section 6651(a)(1) addition to tax for 1991; (3) whether            
          petitioners are liable for the section 6651(f) additions to tax             
          for 1992 and 1993 for failure to file due to willful intent to              
          evade income taxes; (4) whether, in the event it is decided that            
          the failure to timely file was not due to willful intent to evade           
          income taxes, petitioners are liable for the delinquency penalty            
          under section 6651(a)(1) for 1992 and 1993; (5) whether                     
          petitioners are liable for the section 6663(a) fraud penalty for            
          1991; and (6) whether, in the event it is decided the                       






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