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Benjamin H. Robson
& Diane E. Robson
Docket No. 23456-94
Penalty
Year Deficiency Sec. 6662(a)1
1990 $17,033 $194
1991 20,629 205
1992 18,035 256
1Respondent conceded that no amounts are due for penalties.
Leroy C. Trnavsky
& Helen E. Trnavsky
Docket No. 23884-94
Penalty
Year Deficiency Sec. 6662(a)1
1990 $13,685 $205
1991 11,776 222
1992 13,789 259
1Respondent conceded that no amounts are due for penalties.
All section 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, unless otherwise
indicated.
The cases have been consolidated for trial, briefing, and
opinion. After concessions, the issues for decision are:
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