Thomas L. Freytag and Sharon N. Freytag - Page 2

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               William D. Elliott, for petitioner Sharon N. Freytag.                  
               James R. Turton, for respondent.                                       
                                       OPINION                                        
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Carleton D. Powell pursuant to the provisions of section              
          7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with            
          and adopts the opinion of the Special Trial Judge that is set               
          forth below.                                                                
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               POWELL, Special Trial Judge:  This matter is before the                
          Court on the motion for summary judgment of petitioner Sharon N.            
          Freytag (Mrs. Freytag or petitioner), filed August 20, 1996.  The           
          facts may be summarized as follows.                                         
               By notice of deficiency issued February 10, 1986, respondent           
          determined deficiencies in petitioners' Federal income taxes and            
          additions to tax as follows:                                                
                                        Additions to Tax                              
          Year      Deficiency    Sec. 6653(a)(1)   Sec. 6653(a)(2)                   
          1978      $5,000              $250                -0-                       
          1981      53,598              2,680      50% of the interest                
                                                  due on $53,598                      
          1982      36,901              1,845     50% of the interest                 
                                                  due on $36,901                      
               On May 12, 1986, petitioners filed a petition for                      
          redetermination of the deficiencies and additions to tax.  At               

               1    Unless otherwise indicated, 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.                                                                  




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