Estate of Mark R. Woodward, Deceased, Lillian H. Woodward, Executrix, and Lillian H. Woodward - Page 2

          Rules 180, 181, and 183.1  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:  Respondent determined                     
          deficiencies in petitioners' Federal income taxes and additions             
          to tax for the taxable years as follows:                                    
                               Additions to Tax                                       
                             Sec.       Sec.     Sec.      Sec.                      
          Year   Deficiency    6653(a)  6653(a)(1) 6653(a)(2) 6659(a)                 
          1980    $10,180     $509   ---          ---    $3,054                       
          1981      9,620           --- $481           1    2,886                     
          1982        700     ---       35           2      ---                       
          1983        755          ---  38           3      ---                       
          1 50 percent of the interest due on $9,620.                                 
          2 50 percent of the interest due on $700.                                   
          3 50 percent of the interest due on $755.                                   
               Respondent also determined that petitioners are liable for             
          the increased rate of interest under section 6621(c) for the                
          taxable years 1980 and 1981.                                                
               After concessions by the parties,2 the only issue remaining            


          1 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.                                                     
          2 Petitioner Estate of Mark R. Woodward, Deceased, concedes                 
          all of the determinations set forth in the notice of deficiency             
          except for the additions to tax under sec. 6659(a) for the                  
          taxable years 1980 and 1981.  For the taxable years 1980 and                
          1981, petitioner Lillian H. Woodward (petitioner) concedes that             
          if petitioner is not an innocent spouse, then she is liable for             
          the deficiencies in tax and additions to tax under secs. 6653(a),           
          6653(a)(1), and 6653(a)(2), and the increased rate of interest              
          under sec. 6621(c) as determined by respondent.  For the taxable            
          years 1982 and 1983, petitioner concedes that she is liable for             
          the deficiencies in tax and additions to tax as determined by               
          respondent.  For the taxable years 1980 and 1981, respondent                
          concedes that petitioners are not liable for the addition to tax            
          under sec. 6659(a).                                                         



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