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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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Last modified: May 25, 2011