- 2 -
1. Held: Trust income is attributed to H and W
for the reasons stated by R.
2. Held, further, H and W omitted nontrust income
and overstated deductions.
3. Held, further, H and W are liable for the
accuracy-related penalty under sec. 6662(a), I.R.C.
4. Held, further, R’s motion to dismiss for lack
of jurisdiction will be granted.
5. Held, further, Ps bear the burden of proof.
Robert Hogue, pro se in docket No. 10400-99.
Michael T. Carey, pro se in docket No. 10502-99.
Jeremy L. McPherson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: These consolidated cases involve
determinations by respondent of deficiencies in, and penalties
with respect to, the Federal income tax liabilities of the
following taxpayers, for the 1995 taxable (calendar) year of
each, in the following amounts:
Penalty
Taxpayer(s) Deficiency Sec. 6662(a)
Res. Mgmt. Svcs. Tr. $65,834 $13,167
Michael & Leone Carey 272,707 54,541
These cases are related in that, under various theories,
respondent believes that there is an identity between Residential
Management Services Trust (the trust) and Michael and Leone Carey
(the Careys or, individually, Michael or Leone). Among other
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011