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our findings and holdings in Steiner v. Commissioner, T.C. Memo.
1995-122.
By notices of deficiency issued September 28, 1992,
respondent determined deficiencies in Federal individual income
tax and additions to tax under sections 6653(a) (negligence,
etc.) and 6661 (substantial understatement of income tax) against
petitioners as follows:
Additions to tax
Sec. Sec. Sec.
Petitioner Year Deficiency 6653(a)(1) 6653(a)(2) 6661
Beaton 1985 $119,550 $5,978 1 $29,888
Steiner 1985 53,335 2,667 1 13,334
1 50 percent of the interest due on the entire deficiency.
Background
When the petition was filed in docket No. 28181-92, Shirley
Beaton resided in Rancho Mirage, California. James A. Beaton
resided in Reno, Nevada, when he died. When the petition was
filed in docket No. 28182-92, Alan B. Steiner and Barbara W.
Steiner resided in Italy.
James A. Beaton (hereinafter sometimes referred to as
Beaton) was a senior vice president of VeloBind, Inc.
(hereinafter sometimes referred to as VeloBind) from April 1983
until May 1, 1986, when he retired. Alan B. Steiner (hereinafter
sometimes referred to as Steiner) was a director of VeloBind from
1979 until November 1991.
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