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penalties with respect to petitioners’ Federal income taxes:2
Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia
and Carol Ann Gouveia, a.k.a. Carol Gouveia, docket No. 288-03
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1995 $30,521 $6,104
1996 22,947 4,589
Greg Gouveia and Carol Gouveia, docket No. 562-03
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1997 $20,620 $4,124
1998 21,982 4,396
Pago Trust, Phillip Norton, Trustee, docket No. 563-03
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1998 $39,331 $7,866
McKenzie Trust, Charles Boatright, Trustee, docket No. 564-03
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1998 $1,136 $227
Petitioners filed separate petitions to redetermine the
deficiencies and related penalties. We consolidated these cases
(hereinafter this case) for trial, briefing, and opinion pursuant
to Rule 141(a) because they present common issues of fact and
law.
2All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Monetary amounts are
rounded to the nearest dollar.
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Last modified: May 25, 2011