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deficiencies and additions to tax regarding both petitioners and
accuracy-related penalties regarding petitioner Charol L.
Stafford (Mrs. Stafford) as determined in the notices of
deficiency. These cases were consolidated for trial, briefing,
and opinion pursuant to the Court's order dated August 7, 1996.
Respondent determined the following Federal income tax
deficiencies, additions to tax, and penalties with respect to
Mrs. Stafford:
Additions to Tax and Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1989 $ 3,539 --- $ 708
1990 10,521 --- 1,490
1991 2,066 $104 ---
1992 3,700 642 ---
1993 1,524 --- ---
Respondent determined the following Federal income tax
deficiencies and additions to tax with respect to petitioner
James E. Stafford (Mr. Stafford):
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1989 $ 3,539 $ 885 $239
1990 11,440 2,092 34
1991 2,066 104 ---
1992 3,700 240 ---
1993 1,721 100 ---
Background
The deficiencies in income taxes are based on respondent's
determinations that petitioners failed to report income in the
following respects: (1) Although Mrs. Stafford filed Federal
income tax returns for the tax years 1989, 1990, and 1993
reporting wage income earned in her individual capacity, she
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