- 2 -
Held, further, Ps are liable for an addition to tax for
failure to file timely returns under sec. 6651(a)(1),
I.R.C., for 1988 and 1989.
Held, further, Ps are liable for an addition to tax for
failure to pay estimated taxes under sec. 6654, I.R.C., for
1988 and 1989.
Held, further, W does not qualify for innocent
spouse relief under sec. 6013(e), I.R.C.
Ismael Gonzalez, for petitioner Hugh Wilkinson.
Melvin Duke, for petitioner Evelyn Wilkinson.
Theresa G. McQueeney, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Hugh Wilkinson (Dr. Wilkinson) and Evelyn
Wilkinson (Mrs. Wilkinson) petitioned the Court to redetermine
respondent's determination with respect to their 1988 through
1990 taxable years. Respondent determined and reflected in a
notice of deficiency dated November 3, 1995, the following
deficiency, additions to tax, and penalties:
Additions to Tax Penalties
Sec. Sec. Sec. Sec.
Year Deficiency 6651(f) 6653(b)(1) 6661 6662
1988 --- --- $97,845 $32,615 ---
1989 $29 $105,978 --- --- $29,856
1990 --- 135,597 --- --- 36,183
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011