Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 2

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               Respondent determined additions to petitioners' Federal                
          income tax as follows:                                                      
                    Additions to Tax                                                  
          Tax Year  Sec. 6653(a)(1)(A)  Sec. 6653(a)(1)(B)  Sec. 6661                 
          1986           $303                1              $1,514                    
          1    50 percent of the interest due on $6,054.                              
               The issues for decision are: (1) Whether petitioners are               
          liable for the additions to tax for negligence under section                
          6653(a)(1)(A) and (B); and (2) whether petitioners are liable for           
          an addition to tax under section 6661.                                      
               Some of the facts have been stipulated and are so found.               
          For clarity and convenience, the findings of fact and opinion               
          have been combined.  Petitioner Michael J. Heckler (petitioner)             
          resided in Kenmore, New York, and petitioner Charlotte A. Miska             
          resided in Oyster Bay, New York, at the time they filed their               
          petition.  Petitioner and Miska were husband and wife during the            
          taxable year in issue.                                                      
               As this Court previously observed in ruling on procedural              
          matters in this case, our jurisdiction is limited to                        
          redetermining petitioners' liability for the additions to tax set           
          forth in the affected items notice of deficiency.  Heckler v.               
          Commissioner, T.C. Memo. 1996-521.  The notice of deficiency                
          shows it was based on a corrected tax liability of $18,366 and              
          that the tax shown on the return or as previously adjusted was              
          $12,312.                                                                    






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