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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By one statutory notice of deficiency dated
January 27, 1992, respondent determined deficiencies and
additions to tax against petitioner Walter J. Van Eck as follows:
Additions to Tax
Sec. Sec.
Sec. 6653(a)(1) 6653(a)(2)
Year Deficiency 6651(a) or (a)(1)(A) or (a)(1)(B)
1982 $105,573 $26,393 $5,279 50% of interest
due on $105,573
1983 94,619 23,655 4,731 50% of interest
due on $94,619
1984 83,407 20,852 4,170 50% of interest
due on $83,407
1985 127,780 31,945 6,389 50% of interest
due on $127,780
1986 284,216 71,054 14,211 50% of interest
due on $284,216
By a second statutory notice of deficiency dated January 27,
1992, respondent determined deficiencies and additions to tax
against petitioners Walter J. and Friedgard V. Van Eck as
follows:
Additions to Tax
Sec.
6653(a)(1)(A) Sec. Sec.
Year Deficiency or (a)(1) 6653(a)(1)(B) 6661
1987 $55,593 $2,780 50% of interest ---
due on $55,593
1988 69,017 3,106 --- $15,529
In her notices of deficiency, respondent explained the
adjustments giving rise to her determinations of deficiency.
Principally, those adjustments were based upon: (1) Amounts
realized from the disposition of real property, (2) a bank
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