Richard W. Kochansky and Monica L. Miller, f.k.a. Monica L. Kochansky - Page 2

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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:  This matter is before the                         
            Court on respondent's motion for entry of decision as to which                            
            Richard W. Kochansky (petitioner) has filed an objection.  In two                         
            notices of deficiency, respondent determined the following                                
            deficiencies, additions to tax, and penalties for the years                               
            indicated:2                                                                               
                          Additions to Tax                                                            
            Sec.          Sec.      Sec.       Sec.                                                   
            Year    Deficiency  6651(a)(1)     6653(a)     6654    6662(b)(1)                         
            1988      $8,115      $2,029        $406        $36        --                             
            1989       4,035         967          --         --       $807                            
            1990       2,022         --           --         --        404                            
            At the time the petition was filed, petitioners were legal                                
            residents of Idaho.                                                                       
                  On the date this case was calendared for trial, the parties                         
            filed with the Court a written stipulation to be bound (the                               
            stipulation).  There was no evidence adduced on that date other                           
            than the stipulation and the exhibits attached thereto.                                   


            1  Unless otherwise indicated, section references 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.                          
            2  The deficiencies, additions to tax, and penalty for the years                          
            1988 and 1990 are against Richard W. Kochansky alone.  For 1989,                          
            the deficiency, addition to tax, and penalty are against Richard                          
            W. Kochansky and Monica L. Miller.                                                        




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