- 3 -
7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
WOLFE, Special Trial Judge: Respondent determined
deficiencies in and additions to petitioners' Federal income
taxes as follows:
Additions to Tax
Petitioners Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(1) Sec. 6659
Glassley 1981 $20,222.00 $1,011.00 1 -
Mahoney 1981 23,283.00 1,164.15 2 $6,984.90
Houser 1981 19,476.06 1,337.12 3 -
1982 160.00 277.35 4 -
150 percent of the interest due on $20,222.
250 percent of the interest due on $23,283.
350 percent of the interest due on $19,476.06.
450 percent of the interest due on $160.
In the statutory notices of deficiency for petitioners Stephen H.
Glassley and Judith S. Glassley (petitioners Glassley) and
petitioner Paul S. Mahoney (Dr. Mahoney), respondent also
determined that the provision for increased interest under
section 6621(c)3 applied. Subsequently, respondent asserted by
first amendment to answer that petitioners Edward F. Houser, Jr.,
2 All section references are to the Internal Revenue Code in
effect for the tax years in issue, except as otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
3 Sec. 6621(c) was repealed by sec. 7721(b) of the Omnibus
Budget Reconciliation Act of 1989 (OBRA 89), Pub. L. 101-239, 103
Stat. 2106, 2399, effective for tax returns due after Dec. 31,
1989, OBRA 89 sec. 7721(d), 103 Stat. 2400. The repeal,
therefore, does not affect the instant cases.
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