Andrew and Margita Zards et al. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  These cases have been consolidated for                
          trial, briefing, and opinion.  Respondent has determined                    
          deficiencies in income tax and additions to tax as follows:                 
          Andrew and Margita Zards - Docket No. 20388-91                              
                  Additions To Tax                                                    
                                       Sec.             Sec.                         
          Year   Deficiency   6653(a)(1)(A)    6653(a)(1)(B)                          
          1986     $2,580         $129               *                                

          Janet Weinman - Docket No. 20389-91                                         
                          Additions To Tax                                            
          Sec.       Sec.         Sec.           Sec.                                 
          Year  Deficiency    6661    6653(a)(1)  6653(a)(1)(A)  6653(a)(1)(B)        
          1986   $42,113    $10,528       ---        $2,106            *              
          1987    13,206      3,302       ---           660            *              
          1988     5,824      1,456      $291          ---            ---             

          Vincent Donahue - Docket No. 20390-91                                       
                                                                                     
                           Additions To Tax                                           
          Sec.      Sec.         Sec.           Sec.                                  
          Year  Deficiency    6661   6653(a)(1)  6653(a)(1)(A)  6653(a)(1)(B)         
          1986   $193,361   $48,408      ---        $9,682            *               
          1987     56,203    14,051      ---         2,810            *               
          1988     27,341     6,835    $1,367         ---            ---              

          Valdis and Vaida Vipulis - Docket No. 2277-93                               
                   Additions To Tax                                                   
                   Sec.          Sec.       Sec.                                     
          Year     6653(a)(1)    6653(a)(2)      6661                                 
          1985       $2,290          **           $11,449                             
          *  50% of sec. 6601 interest due on the deficiency amount.                  
          **  50% of the interest due on $45,797.                                     
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  






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