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MEMORANDUM OPINION
DAWSON, Judge: These consolidated cases were assigned to
Special Trial Judge Carleton D. Powell pursuant to the provisions
of section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court
agrees with and adopts the opinion of the Special Trial Judge
that is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: Respondent determined
deficiencies and additions to tax in petitioners' Federal income
taxes as follows:
I.C. Hemmings and Sue B. Hemmings
Additions to Tax
Docket No. Year Deficiency Sec.6653(a)(1) Sec.6653(a)(2) Sec.6661
41407-85 1978 $1,111,073 $55,554 -- --
1979 2,626,613 131,331 -- --
1980 1,801,785 90,089 -- --
14273-86 1981 3,971,519 198,576 1 --
9710-90 1983 560,882 28,044 2 $140,221
1984 87,362 4,368 3 21,841
1 50 percent of the interest due on $3,971,519.
2 50 percent of the interest due on $560,882.
3 50 percent of the interest due on $87,362.
2 Unless otherwise indicated, 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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Last modified: May 25, 2011