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Respondent reflected this determination in a notice of deficiency
issued to Mrs. Burke on March 23, 1989. Martin M. Burke
petitioned the Court to redetermine respondent's determination of
deficiencies in his 1979 through 1982 Federal income taxes.
Respondent reflected this determination in a notice of deficiency
issued to Mr. Burke on January 12, 1988.
Respondent determined the following deficiencies and
additions thereto:
Datha D. Burke: Docket No. 14139-89
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6659 6661
1979 $65,086 $3,254 --- --- ---
1980 151,493 7,575 --- --- ---
1981 69,030 --- $3,452 --- ---
1982 483,767 --- 24,188 $61,950 $69,317
Martin M. Burke: Docket No. 15957-92
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6659 6661
1979 $68,798 $3,440 --- --- ---
1980 161,063 8,053 --- --- ---
1981 88,298 --- $4,415 --- ---
1982 422,140 --- 21,107 $111,688 $12,462
Respondent also determined that petitioners were liable for
additions to their 1981 and 1982 taxes under section 6653(a)(2),
and that their 1982 income tax liability was subject to an
increased rate of interest under section 6621(c).
The petitions are silent on the appropriateness of the
additions to tax and increased rate of interest determined by
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