Joel L. and Delynn E. Boyce - Page 2

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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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