- 2 - 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. WebberPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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