Duane B. and Linda L. Erwin, et al. - Page 2

            section 7443A(b)(4) and Rules 180, 181, and 183.2  The Court                                   
            agrees with and adopts the Opinion of the Special Trial Judge,                                 
            which is set forth below.                                                                      
                                OPINION OF THE SPECIAL TRIAL JUDGE                                         
                  ARMEN, Special Trial Judge:  Each of these cases is before                               
            the Court on respondent's Motion To Dismiss For Failure To State                               
            A Claim Upon Which Relief Can Be Granted, filed pursuant to Rule                               
            40.                                                                                            
                  Petitioners resided in Independence, Missouri, at the time                               
            their petitions were filed in these cases.                                                     
            Respondent's Notices of Deficiency                                                             
                  By notices dated February 23, 1995, respondent determined                                
            deficiencies in petitioners' Federal income taxes for the taxable                              
            years 1992 and 1993, as well as a penalty and additions to tax,                                
            as follows:                                                                                    
            Docket No. 8625-95                                                                             
            Duane B. and Linda L. Erwin                                                                    
                   Penalty                                                                                 
            Year     Deficiency       Sec. 6662(a)                                                         
            1992     $14,029            $2,799                                                             
            Docket No. 8626-95                                                                             
            Duane B. Erwin                                                                                 
                        Additions to tax                                                                   
            Year     Deficiency       Sec. 6651(a)     Sec. 6654(a)                                        
            1993     $4,363              $1,156              $183                                          

            2 Unless otherwise indicated, all section references are to                                    
            the Internal Revenue Code in effect for the taxable years in                                   
            issue, and all Rule references are to the Tax Court Rules of                                   
            Practice and Procedure.                                                                        





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