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