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Jerold A. Reiton and Alan James Pinner, for petitioners.
Andrew P. Crousore, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Khosrow Ghadiri (Mr. Ghadiri) and Turan
Mirhady Ghadiri (Mrs. Ghadiri) petitioned the Court to
redetermine respondent's determination of the following Federal
income tax deficiencies and additions thereto:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A)6653(a)(1) 6653(a)(1)(B)
1986 $227,086 $56,771 $11,354 --- 50% of the
interest due
on $227,086
1987 143,674 35,919 7,184 --- 50% of the
interest due
on $143,674
1988 33,251 8,313 --- $1,663 ---
Respondent later adjusted these deficiencies to the amounts
stated below. Respondent conceded that the additions to tax
should be adjusted to reflect the revised deficiencies.
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A)6653(a)(1) 6653(a)(1)(B)
1986 $129,159 $56,771 $11,354 --- 50% of the
interest due
on $268,589
1987 75,428 35,919 7,184 --- 50% of the
interest due
on $260,736
1988 41,969 8,313 --- $1,663 ---
Following concessions, we must decide:
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