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MEMORANDUM OPINION
DINAN, Special Trial Judge: These consolidated cases were
heard pursuant to the provisions of section 7443A(b)(3) and Rules
180, 181, and 182.1
Respondent determined additions to petitioners' Federal
income taxes for the years as indicated:
Catherine Chimblo and Estate of Gus Chimblo, Deceased, Catherine
Chimblo, Executrix, docket No. 16546-96
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1980 $479 * ---
1982 60 * ---
1983 619 * $3,097
1984 629 * 3,144
*50% of the interest due on the deficiency.
Josephine Chimblo and Estate of Anthony J. Chimblo, Deceased,
Rosalie Monahan, Executrix, docket No. 16804-96
Year Sec. 6653(a)(1) Sec. 6653(a)(2)
1980 $595 *
1981 $334 *
*50% of the interest due on the deficiency.
The issues for decision are: (1) Whether respondent
properly notified petitioners of the underlying partnership
proceeding which led to the deficiencies upon which the additions
to tax in these cases are based; (2) whether petitioners are
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011