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determined the following deficiencies in income tax, addition to
tax, and accuracy-related penalties:
Addition to TaxAccuracy-Related Penalty
Docket No. Year Deficiency Sec. 6651(a) Sec. 6662
8933-94 1991 $3,466 --- ---
6564-96 1992 3,435 --- ---
1993 2,823 --- ---
26100-96 1994 2,946 $737 $589
1995 4,860 --- 972
After concessions by petitioners, including the section 6651
addition to tax, the issues for decision in these consolidated
cases are: (1) Whether petitioners are entitled, on the basis of
section 104(a)(2), to exclude the entire $36,000 payment, or a
portion thereof, that petitioner David R. Green received pursuant
to a settlement agreement, and (2) whether petitioners are liable
for accuracy-related penalties under section 6662 for taxable
years 1994 and 1995.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Salt Lake City, Utah, at the time the petition was filed in
docket No. 8933-94; petitioner David R. Green resided in
Chandler, Arizona, and petitioner Carolyn B. Green resided in
Salt Lake City, Utah, at the time the petition was filed in
docket No. 6564-96; and petitioner David R. Green resided in
Washington, Utah, and petitioner Carolyn B. Green resided in Salt
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