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MEMORANDUM OPINION
DINAN, Special Trial Judge: These consolidated cases were
heard pursuant to the provisions of section 7443A(b)(3) and Rules
180, 181, and 182.2
Respondent determined deficiencies in petitioners' Federal
income taxes and accuracy-related penalties pursuant to section
6662(a) as follows:
Eli T. Sleiman, Jr. and Janie L. Sleiman, docket No. 12663-95
Penalty
Year Deficiency Sec. 6662(a)
1992 $3,544 $709
Peter D. Sleiman and Carolina T. Sleiman, docket No. 12664-95
Penalty
Year Deficiency Sec. 6662(a)
1991 $3,332 $666
1992 4,286 857
Anthony T. Sleiman and Bonnie C. Sleiman, docket No. 12665-95
Penalty
Year Deficiency Sec. 6662(a)
1991 $2,049 $410
1992 4,174 835
After concessions by the parties, the issues remaining for
decision are: (1) Whether petitioners Eli T. Sleiman and Peter
2 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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