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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. Allen
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