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penalties in regard to petitioners' Federal income tax as
follows:
Milo G. and Sarah E. Chapman--docket No. 20342-94
Addition to Tax and Penalties
Year Deficiency Sec. 6653(a)(1) Sec. 6662(a)
1988 $25,424 $1,237 ---
1989 12,429 --- $2,357
1990 1,574 --- 315
David E. and Gladys A. Christie--docket No. 20363-94
Addition to Tax and Penalties
Year Deficiency Sec. 6653(a)(1) Sec. 6662(a)
1988 $19,469 $973 ---
1989 10,846 --- $2,040
1990 962 --- 192
Dura-Craft, Inc.--docket No. 20560-94
Taxable Year Addition to Tax and Penalty
Ending Deficiency Sec. 6653(a)(1) Sec. 6662(a)
10/31/88 $15,968 $798 ---
10/31/89 93,410 --- $3,591
Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the years at issue,
and Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, the issues for decision are:
(1) Whether petitioners Milo and Sarah Chapman and David and
Gladys Christie received distributions from the Dura-Craft
profit-sharing plan (Plan) in 1988 and 1989 pursuant to section
72(p);
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