Roger Muldavin, et al. - Page 2

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          Roger Muldavin                                                              
                                   Additions to Tax                                   
          Year Deficiency   Sec. 6651 Sec. 6653(a)Sec. 6654 Sec. 6661                 
          1985 $142,578.85 $30,936.52  $7,128.94* $6,798.00 $30,937.00                
          1986  113,423.25  21,292.62   5,671.16* 4,177.00  21,293.00                 
          1987   56,026.00  13,957.00   2,801.00* 3,016.00  ---                       
               *Plus 50 percent of the interest on $123,746.07, $85,170.25, and       
               $56,026.00, for 1985, 1986, and 1987, respectively.                    
          Jean Muldavin                                                               
                                   Additions to Tax                                   
          Year Deficiency Sec. 6651 Sec. 6653(a)  Sec. 6654 Sec. 6661                 
          1985 $143,618.85 $31,196.52  $7,180.94* $6,858.00 $31,197.00                
          1986  114,503.25  21,562.62   5,725.16* 4,231.00  21,563.00                 
          1987   56,026.00  13,957.00   2,801.00* 3,016.00  ---                       
               *Plus 50 percent of the interest on $124,786.07, $86,250.47, and       
               $56,026.00, for 1985, 1986, and 1987, respectively.                    
          Roger and Jean Muldavin                                                     
                                   Additions to Tax                                   
               Year      Deficiency Sec. 6653(a)  Sec. 6661 Sec. 6662                 
               1988      $19,935   $997           $4,984    ---                       
               1989   26,302     ---    ---   $5,260                                  


               This case was submitted by the parties fully stipulated                
          under Rule 122.2  The stipulation of facts and attached exhibits            
          are incorporated herein by this reference.  The submission was              
          accompanied by a stipulation of settled issues and by an                    
          explanation by the parties that the sole issue for decision, with           


          2  Unless otherwise indicated, all statutory 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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