David Carkhuff and Tonja Carkhuff - Page 2

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               Respondent determined deficiencies in, an addition to, and             
          accuracy-related penalties on, petitioners' Federal income tax              
          for taxable years 1990 and 1991 as follows:                                 
                                  Addition to Tax  Accuracy-Related                  
                                       Sec.         Sec.                             
          Year      Deficiency          6651(a)        6662(a)1                       
          1990      $7,594              $1,730.75      $1,518.80                      
          1991      44,731             --        8,946.20                            
               1 The first page of the statutory notice of deficiency                 
          mistakenly refers to the accuracy-related penalties determined in           
          1990 and 1991 as pursuant to sec. 6651; however, the explanation            
          pages of the notice of deficiency refer to the correct section,             
          For the reasons discussed below, the Court will grant                       
          respondent's motion.                                                        
                                   FINDINGS OF FACT                                   
               At the time the petition in this case was filed, petitioners           
          resided in Concord, California.  Petitioners requested San                  
          Francisco, California, as the place for trial at the time they              
          filed their petition.                                                       
               On September 21, 1994, respondent issued a statutory notice            
          of deficiency to petitioners for tax years 1990 and 1991.  The              
          deficiencies at issue are attributable to respondent's                      
          determination that (1) petitioners failed to report gross                   
          receipts; (2) petitioners failed to report a taxable IRA                    
          distribution and are liable for additional tax on an early                  
          distribution from the IRA; (3) petitioners are liable for                   
          additional self-employment tax; (4) petitioners have not                    

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