- 2 - 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 NAMEROFF, Special Trial Judge: This case is before us on respondent's Motion to Dismiss for Failure To State A Claim and To Impose A Penalty Under Section 6673. Respondent determined the following deficiencies and additions to tax with respect to petitioner Joel L. Boyce: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec.6654(a) 1991 $47,204 $11,801 $2,493 1992 35,173 8,793 1,536 1993 49,278 12,320 1,891 In addition, respondent determined the following deficiencies and additions to tax with respect to petitioner DeLynn E. Boyce: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1991 $19,209 $4,802 $882 1992 13,852 3,463 606 1993 18,503 4,626 604 The adjustments giving rise to the above deficiencies and additions to tax are based upon the failure of petitioners to file Federal income tax returns and report gross receipts from State Farm Insurance, dividend income, interest income, a 1 All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011