Mark N. Wright and Erica Y. Wright - Page 2

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                    Held, further, Ps are liable for the additions to                 
               tax pursuant to sec. 6651(a)(1), I.R.C., for 1999 and 2000.            
                    Held, further, P-H is liable for the civil fraud                  
               penalty pursuant to sec. 6663, I.R.C., for 1999, 2000,                 
               and 2001.                                                              

               Mark and Erica Wright, pro sese.1                                      
               Stephen R. Takeuchi, for respondent.                                   


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WHERRY, Judge:  This case is before the Court on a petition            
          for judicial review of a notice of deficiency issued November 23,           
          2004, to both petitioners for their 1999, 2000, and 2001 taxable            
          years.  Respondent determined the following Federal income tax              
          deficiencies, additions to tax, and penalties for petitioner Mark           
          N. Wright’s (Mr. Wright) 1999, 2000, and 2001 taxable years:2               
                                        Addition to Tax     Penalty                   
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6663                 
               1999      $34,194.00     $8,528.25           $25,645.50                
               2000      4,183.00       416.00              3,137.25                  
               2001      10,495.00           --             7,870.95                  




               1Petitioners were represented by William Randolph Klein at             
          trial, on briefing, and until his death on Nov. 27, 2006.                   
               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code (Code) in effect for the years in                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     






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