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F. Michael Kovach, Jr., for petitioners.
Cathy A. Goodson, for respondent.
OPINION
HALPERN, Judge: By notice of deficiency dated April 14,
1995, respondent determined a deficiency in petitioners' Federal
income tax for 1991 of $161,055 and a penalty under section
6662(a) of $32,211. Unless otherwise noted, all section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure. In addition, all references to
petitioner are to John M. Monahan.
After concessions by respondent, the issues for decision are
(1) whether certain interest payments that were credited to a
partnership's bank account are taxable to petitioners,
(2) whether a $25,000 payment that was deposited in petitioners'
bank account is taxable to petitioners, and (3) whether
petitioners are liable for the penalty. The parties have
stipulated various facts, which we so find. The stipulation of
facts, with accompanying exhibits, is incorporated herein by this
reference. We need find few facts in addition to those
stipulated; accordingly, we shall not separately set forth our
additional findings of fact and shall include those findings in
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