- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: Respondent determined deficiencies in income tax and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a)(1) Bruce and Jean Korson 1991 $10,000 $396 Armin B. Allen 1991 5,484 -- John H. and Susan N. Allen 1991 9,415 -- Petitioners have assigned error to respondent’s determinations and, in addition, have claimed overpayments in tax. Petitioners Bruce and Jeanne Korson concede the section 6651(a)(1) addition to tax, and the only other issue for decision, common to all petitioners, is the fair market value of certain property contributed to charity. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Introduction Some of the facts have been stipulated and are so found. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. At the time the petitions in these cases were filed, petitioners Bruce and Jeanne Korson resided in Oyster Bay Cove, New York, petitioner Armin B. AllenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011