Patrick Carlin Hickey, et al. - Page 2

                                         -2-                                          
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioners petitioned the Court to                      
          redetermine certain determinations made by respondent as to their           
          Federal income tax liabilities.  The Court consolidated the cases           
          for purposes of trial, briefing, and opinion.  Inasmuch as                  
          petitioner Sharon JoAnn Hickey is involved in these cases because           
          she filed joint 1992 and 1993 Federal income tax returns with               
          petitioner Patrick Carlin Hickey, we hereinafter use the singular           
          “petitioner” to refer solely to Patrick Carlin Hickey.  We refer            
          to Sharon JoAnn Hickey as “Hickey”.  Unless otherwise noted,                
          section references are to the applicable versions of the Internal           
          Revenue Code, and Rule references are to the Tax Court Rules of             
          Practice and Procedure.                                                     
               In docket Nos. 9582-04 and 9592-04, petitioner petitioned              
          the Court on June 8, 2004, to redetermine respondent’s                      
          determination of the following deficiencies, additions to tax,              
          and penalties:                                                              
          Additions to tax           Penalty                                          
           Year   Deficiency  Sec. 6651(a)(1)  Sec. 6654     Sec. 6663                
          1989     $23,621        $5,201         $507        $17,716                  
          1990       2,982           671            0          2,237                  
          1991      23,964         5,392           48         17,495                  
          1992      10,728             0            0          8,046                  
          1993       2,674           165          318          2,006                  
          Respondent reflected this determination in two notices of                   
          deficiency issued to petitioner on March 25, 2004.  Respondent              
          also determined in the notices of deficiency that petitioner is             





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