Victor Grigoraci and Judith A. Grigoraci, et al. - Page 2




                                          2                                           
                      MEMORANDUM FINDINGS OF FACT AND OPINION                         
               LARO, Judge: These cases were consolidated for trial,                  
          briefing, and opinion.  In docket No. 7628-00, Victor and Judith            
          A. Grigoraci (separately Mr. Grigoraci and Mrs. Grigoraci,                  
          respectively, and collectively the Grigoracis) sought                       
          redetermination under section 6213 of a deficiency for tax on               
          self-employment income and a negligence accuracy-related penalty            
          under section 6662(a).2  Respondent determined a deficiency of              
          $12,670 and an accuracy-related penalty of $2,534 for 1996.                 
               In docket numbers 7890-00 and 9573-00, petitions were                  
          brought under section 6226 by the Tax Matters Partners of two               
          partnerships: Trainer, Wright & Associates (TWA) and Grigoraci,             
          Trainer, Wright & Paterno (GTWP).3  The petitioners in these                
          cases sought readjustment of certain adjustments made by                    
          respondent to the partnerships’ 1996 tax returns.                           
               Both partnerships reported on Schedules K-1, Partner’s Share           
          of Income, Credits, Deductions, Etc., that the partners in each             
          partnership were corporations.  Respondent determined that the              
          partners of record were not the true and actual partners, but               




               2  Unless otherwise indicated, section references are to the           
          Internal Revenue Code applicable to the subject years.  Rule                
          references are to the Tax Court Rules of Practice and Procedure.            
               3  Paterno is not a partner to GTWP.  The partnership                  
          adopted the use of the Paterno name after purchasing a firm by              
          the name of Howell and Paterno.                                             




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