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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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