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income tax of petitioner Ghalardi Income Tax Education
Foundation:
Year Deficiency Penalty Sec. 6662(a)
1993 $14,334 $2,866
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect for the years in issue.
Respondent also determined the following deficiencies in,
addition to, and penalties with respect to the Federal
income tax of William S. Webber, Jr.:
Addition to Tax
Year Deficiency Penalty Sec. 6662 Sec. 6651(a)(1)
1992 $19,404 $3,881 -0-
1993 27,426 5,485 $1,371
These cases were consolidated for trial, briefing, and
opinion by order of the Court issued pursuant to Rule
141(a) of the Tax Court Rules of Practice and Procedure.
In this opinion all Rule references are to the Tax Court
Rules of Practice and Procedure.
The issue for decision in this case is whether
respondent properly determined the subject tax
deficiencies, penalties, and addition to tax.
FINDINGS OF FACT
Mr. Webber filed Forms 1040, U.S. Individual Income
Tax Return, for 1992 and 1993. On each return, Mr. Webber
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