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Rules 180, 181, and 183.1 The Court agrees with and adopts the
opinion of the Special Trial Judge which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: Respondent determined the
following deficiencies in petitioners' Federal income taxes and
additions to tax:
Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1989 $11,135 $2,154.85
1990 12,800 2,383.00
1991 6,984 981.00
1992 6,881 1,984.00
After concessions by the parties, the issues remaining for
decision are: (1) Whether Mary Ann Collins (petitioner)
overstated gross receipts or sales income from her trade or
business activity for the years 1989 and 1990; (2) whether
petitioners are entitled to a child care credit under section 21
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
Petitioners elected that this case be considered as a small tax
case pursuant to sec. 7463. Prior to commencement of the trial,
the Court ordered the discontinuance of the proceedings under
sec. 7463 because the deficiencies in tax for 2 of the years in
question were in excess of $10,000, and the allegations in the
petition placed at issue the entire amounts of the deficiencies
and additions to tax determined in the notices of deficiency.
The Court thereupon assigned the case to the Special Trial Judge
pursuant to sec. 7443A(b)(4). Respondent filed an answer,
generally denying petitioners' allegations.
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