- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011