2
prescribed by section 6213(a).1 The motions were assigned for
hearing pursuant to section 7443A(b)(4) and Rules 180, 181, and
183. A hearing was held on respondent's motions in Houston,
Texas.
On March 26, 1997, respondent issued and mailed to each
petitioner a separate notice of deficiency. In each notice,
respondent determined the following deficiencies and additions in
Federal income taxes:
Petitioner Theodore Jones
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a) 6654
1991 $43,943 $10,986 $2,511
1992 92,037 23,009 4,014
1993 32,932 8,233 1,380
Petitioner Catherine Allen-Jones
Additions to Tax
Sec. Sec.
Year Deficiency 6651(f) 6654
1991 $52,602 $39,452 $3,006
1992 101,043 75,782 4,407
1993 41,931 31,448 1,757
The 90-day period for filing a petition with this Court
expired on Tuesday, June 24, 1997, which was not a legal holiday
in the District of Columbia.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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