Tyson Bonty and Torie A. Stephens - Page 2

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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                      
               Year           Deficiency          Sec. 6662(a)                        
               1994           $8,729              $1,746                              
          Tyson Bonty, docket No. 19641-96                                            
               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.                                         
               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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