- 2 - agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: These related cases are before the Court on the parties' cross-motions for summary judgment. As explained in more detail below, we will grant respondent's motions for summary judgment. Background On May 12, 1989, respondent mailed a statutory notice of deficiency to Frederick M. Fox (petitioner) and his former spouse, Michelle B. Fox, determining deficiencies in and additions to their Federal income taxes for the taxable years 1982, 1983, 1984, and 1985. On that same date, respondent mailed a separate statutory notice of deficiency to petitioner determining a deficiency in and additions to his Federal income tax for the taxable year 1986. Respondent's determinations are summarized in the following table: Year Deficiency 6653(a)(1) 6653(a)(2) 6653(b)(1) 6653(b)(1)(A) 6653(b)(2) 6653(b)(1)(B) interest due on $775 interest due on $10,864 interest due on $19,376Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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