- 2 -
Kathleen L. Donohue, Ellen T. Friberg, and Eli J. Dicker,
for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined deficiencies in
petitioners' Federal income taxes and additions to tax for the
taxable years 1985 to 1987 as follows:
1. Jack S. & Maxine C. Kramer--docket No. 22457-91
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2)
1985 $25,766 $10,191.50 $2,304.75 1
1Equals 50 percent of interest due on the entire deficiency.
2. Jack J. Kramer--docket No. 22785-90
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6654 6661
1986 $338,783 $254,087 1 $15,981 $84,696
1987 69,977 52,483 1 3,571 17,494
150 percent of the statutory interest applicable on $338,783 and $69,997
for 1986 and 1987, respectively, from the due date of the return to the date
of assessment of the tax or, if earlier, the date of the payment.
After concessions, the following deficiencies and additions
remain in dispute:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2)
1985 $25,177 $6,294.25 $2,275.30 1
1Equals 50 percent of interest due on the amount of the deficiency.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011