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are to the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. The Court agrees with and adopts the
Special Trial Judge's opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
CARLUZZO, Special Trial Judge: Respondent determined
deficiencies, additions to tax, and increased interest with
respect to Romine C. and Wanda L. Hogard's Federal income taxes
as follows:
Additions to Tax and Increased Interest
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c)
1979 $22,580.00 $1,129.00 --- --- $6,774.00 2
1980 28,358.00 1,417.90 --- --- 8,507.40 2
1981 28,662.00 --- $1,433.10 1 8,598.60 2
1982 15,366.40 --- 768.32 1 4,609.92 2
1 50 percent of the interest due on the deficiency.
2 Interest on the entire deficiency to be computed at 120 percent of the
standard underpayment rate.
Respondent determined deficiencies, additions to tax, and
increased interest with respect to Gilmore & Wilson Construction
Co. & Subsidiary's Federal income taxes as follows:
Additions to Tax and Increased Interest
Sec. Sec. Sec. Sec. Sec.
TYE Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c)
7/31/80 $27,845.00 1,392.25 --- --- $8,353.50 2
7/31/81 10,595.20 --- $529.76 1 3,178.56 2
7/31/83 --- --- 2,149.31 1 12,895.84 2
1 50 percent of the interest due on the deficiency.
2 Interest on the entire deficiency to be computed at 120 percent of the
standard underpayment rate.
Respondent determined deficiencies, additions to tax, and
increased interest with respect to Charles T. and Bettye
Gilmore's Federal income taxes as follows:
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