- 2 - vacating and remanding in part without published opinion T.C. Memo. 1993-232. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1982, and all Rule references are to the Tax Court Rules of Practice and Procedure. All references to petitioner, singular, are to Gary A. Bybee. In Bybee v. Commissioner, T.C. Memo. 1993-232, we sustained respondent's Federal income tax deficiency determinations and additions to tax for 1982, 1983, and 1984, as reflected in the schedule below: Additions to Tax Year Deficiency Sec. 6653(a)(1)Sec. 6653(a)(2)Sec. 6661 1982 $11,047 $552 * $1,105 1983 13,503 675 * 1,350 1984 11,957 598 * 1,196 * 50 percent of interest due on portion of underpayment attributable to negligence. In Bybee v. Commissioner, supra, the Court of Appeals for the Ninth Circuit affirmed our decision relating to petitioners' 1983 and 1984 Federal income tax deficiencies and additions to tax. With regard, however, to our decision relating to petitioners' 1982 Federal income tax deficiency and additions to tax, the Court of Appeals for the Ninth Circuit questioned whether respondent's notice of deficiency was timely mailed pursuant to section 6501(a) and remanded that question to us for our consideration.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011