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Respondent determined deficiencies in petitioners' Federal
income taxes and penalties as follows:
Tyson Bonty and Torie A. Stephens, docket No. 19640-96
Penalty
Year Deficiency Sec. 6662(a)
1994 $8,729 $1,746
Tyson Bonty, docket No. 19641-96
Penalty
Year Deficiency Sec. 6662(a)
1992 $4,214 $843
1993 13,031 2,606
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the taxable years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Respondent filed the instant motions, and petitioners filed
objections to respondent's motions.
Background
At the time petitioners filed their petitions in the instant
cases, petitioners resided in Doraville, Georgia.
During or about March 1996, petitioners moved to 1408 Brook
Court Avenue in Doraville, Georgia (the Brook Court address). On
or before April 15, 1996, petitioners filed with the Internal
Revenue Service Center in Atlanta, Georgia, their 1995 joint
Federal income tax return, which listed the Brook Court address
as their address.
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