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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Docket Nos. 142-95 and 22884-95 are before the
Court consolidated for purposes of trial, briefing, and opinion.
Joseph Chu and Annie Chu petitioned the Court to redetermine
respondent's determination of the following Federal income tax
deficiencies and additions thereto:
Penalties
Year Deficiency Sec. 6662(a)
1990 $193,739 $38,209
1991 727,937 145,587
In an amendment to answer, respondent alleged that the
deficiency and penalty determined in the notice of deficiency for
1990 should be increased to reflect $9,619 of unreported interest
income that petitioners earned on a foreign bank account.
Petitioners concede the correctness of this allegation.
Upon motion of respondent at the close of trial, the Court
amended the pleadings to conform to the evidence. See Rule
41(b)(1). Respondent alleged that the evidence will show that
petitioners received another $10,000 of gross income in 1990, and
that the deficiency and penalty for that year should be increased
accordingly.
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