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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