Rodney W. and Lynnell R. Frazier - Page 2




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                                                        Accuracy-related               
          Years               Deficiency                Penalty Sec. 6662              
          1993                $6,412                         $1,282                    
          1994                9,140                          1,828                     
          1995                4,420                          884                       

               All section references are to the Internal Revenue Code in              
          effect in the years in issue.  All Rule references are to the Tax            
          Court Rules of Practice and Procedure.  All dollar amounts are               
          rounded.                                                                     
               Some of the facts have been stipulated and are so found and             
          incorporated by this reference.                                              
               At the time the petition was filed, petitioners were married            
          and living in Hueytown, Alabama.                                             
               During the years at issue, petitioner husband operated a                
          business known as Pro TV & VCR Repair.  In 1993, petitioner                  
          husband filed a Federal income tax return with a filing status of            
          single.                                                                      
               In 1994, petitioners were married.  During the years at                 
          issue, petitioner wife was employed at the Alabama Power Co.  In             
          1994 and 1995, petitioners filed joint Federal income tax                    
          returns.                                                                     
               Petitioner husband’s tax return for 1993, and petitioners’              
          joint tax returns for 1994 and 1995, reported income as follows:             








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