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deficiencies in and additions to petitioners' Federal income tax:
Howard and Alice Berger (Docket Nos. 3130-93 and 2464-93):
Addition to tax
Year Deficiency Sec. 6653(a)(1)
1988 $155,646 $7,782
Alice Berger (Docket No. 2464-93):
Addition to tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1989 $307,202 $76,801 $61,440
Howard and Susan Berger (Docket No. 3133-93):
Addition to tax
Year Deficiency Sec. 6651(a)(1)
1989 $68,801 $23,577
The cases in the above-mentioned dockets have been
consolidated for trial, briefing, and opinion. Following the
trial, we granted respondent's motion for leave to file an
amended answer asserting the following increased deficiency and
addition to tax against Howard and Susan Berger (Docket No. 3133-
93):
Addition to tax
Year Deficiency Sec. 6651(a)(1)
1989 $237,936 $57,404
Petitioners Howard and Susan Berger did not file a reply to
respondent's amended answer. However, their opening brief
contends that their 1989 return overstated taxable income from
mausoleum crypt sales, none of which, they now assert, should
have been reported by Howard Berger, and asserts an overpayment
of $61,106.
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