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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined deficiencies in
petitioners' Federal income tax and additions to tax as follows:
Doyle A. King
Additions to Tax
Year Deficiency Sec. 6651 Sec. 6654
1990 $9,517 $2,334 $- 0 -
1991 15,473 3,853 878
Nevan Y. King
Additions to Tax
Year Deficiency Sec. 6651 Sec. 6654
1990 $28,908 $7,227 $- 0 -
1991 35,964 8,991 2,050
By Amended Answer, respondent asserts the following
increased deficiencies:
Doyle A. King
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654
1990 $28,291 $6,218 $1,490
1991 28,772
Nevan Y. King
Additions to Tax
Year Deficiecncy Sec. 6651(a) Sec. 6654
1990 $40,317
1991 41,871 10,460 2,406
After concessions, the issues for decision are:
(1) Whether petitioner Doyle A. King (Doyle) received wages of
$2,400 and $1,000 in 1990 and 1991, respectively.
(2) Whether petitioners received interest income of $351 and $750
in 1990 and 1991, respectively.
(3) Whether Doyle had Schedule C income from his Delta Valley
Realty business of $50,831 and $52,971 in 1990 and 1991, respectively.
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