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Stephen M. Miller, for respondent.
HALPERN, Judge: These consolidated cases involve the
following determinations by respondent of deficiencies in,
additions to, and penalties on petitioners' Federal income tax:
Docket No. 21808-93 Michael Ferguson and Valene Ferguson
Additions to Tax and Penalties
Sec. Sec. Sec. Sec.
Year Deficiency 6653 6654 6661 6662
1987 $29,115 -- -- -- $5,823
1988 1,249,580 $36,491 $94,384 $182,456 103,951
1989 117,227 -- -- -- 23,445
1990 75,197 -- -- -- 15,039
1991 66,942 -- -- -- 13,388
Docket No. 18250-94 Roger N. Ferguson and Sybil Ferguson
Additions to Tax and Penalties
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6659 6661 6662(a) 6621(c)
1988 $2,017,297 $170,767$427,524 $163,701 -- 1
1989 160,451 -- -- -- $50,353 --
1991 624,490 -- -- -- 127,120 --
1120% of interest due on $1,425,079
Certain adjustments having been agreed to and concessions made,
the sole issue remaining for decision is whether petitioners are
taxable on the gain in appreciated stock transferred to various
charitable organizations under the anticipatory assignment of
income doctrine.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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