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PARR, Judge: Respondent determined deficiencies in, and
additions to, petitioner Jerry Webb's (petitioner) Federal income
tax for 1990, 1991, and 1992 as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1990 $12,693.00 $ 3,132.50 $ 831.25
1991 17,824.00 4,456.00 1,025.23
1992 19,168.00 1,120.50 249.32
Respondent determined deficiencies in, and additions to,
petitioner Carolyn Webb's (Carolyn Webb) Federal income tax for
1990, 1991, and 19921 as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1990 $ 2,952.00 $ 738.00 $ 194.37
1991 4,139.00 1,034.75 238.07
1992 3,756.00 939.00 163.82
These cases (docket No. 18976-94 involving the income tax of
Carolyn Webb for 1987, 1988, 1989, 1990, 1991, and 1992 and
docket No. 19059-94 involving the income tax of petitioner for
1 Respondent determined that Carolyn Webb had deficiencies in
tax for 1987 through 1992. At trial, and on brief, however,
respondent concedes the deficiencies asserted against Carolyn
Webb for 1987 through 1989 based on two decisions entered by this
Court against petitioner. See Webb v. Commissioner, T.C. Memo.
1993-521, affd. without published opinion 46 F.3d 1149 (9th Cir.
1995); Webb v. Commissioner, T.C. Memo. 1993-283, vacated and
remanded in part without published opinion 28 F.3d 111 (9th Cir.
1994), on remand T.C. Memo. 1995-199, affd. 86 F.3d 1165 (9th
Cir. 1996). Those decisions sustained respondent's
determinations, which attributed 100 percent of the income earned
by petitioner to him. Accordingly, respondent concedes the
deficiencies asserted against Carolyn Webb for 1987, 1988, and
1989.
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