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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011