- 2 -
section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Chief Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: Respondent determined
a deficiency in petitioner Angela Matthews' 1991 Federal income
tax in the amount of $8,362 and an addition to tax in the amount
of $2,091 pursuant to section 6651(a)(1). Respondent also
determined a deficiency in petitioner Richard Matthews' 1991
Federal income tax in the amount of $9,597 and an addition to tax
in the amount of $2,399 pursuant to section 6651(a)(1). Upon
motion by the parties, these two dockets were consolidated for
trial, briefing, and opinion. In her Amendment to Answer in each
docket, respondent asserted an increased deficiency and addition
to tax. Thus, the amounts of the deficiencies and additions to
tax in issue for 1991 are as follows:
Docket No. 16603-94--Angela Matthews
Deficiency Sec. 6651(a)(1) Addition to Tax
$23,255 $5,814
Docket No. 16604-94--Richard L. Matthews
Deficiency Sec. 6651(a)(1) Addition to Tax
$41,316 $10,329
1 All section references are to the Internal Revenue Code
in effect for the year in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011