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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.
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