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Janice Leonard:
Additions to Tax
Year Deficiency Sec. 6651 Sec. 6654
1990 $436 $109 ---
1991 791 198 $45
Matthew and Janice Leonard:
Penalty
Year Deficiency Sec. 6662(b)(1)
1993 $723 $145
1994 5,054 1,011
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.
The issues for decision are: (1) Whether petitioners are
liable for the deficiencies determined by respondent; (2) whether
petitioners are liable for additions to tax for failing to file
Federal income tax returns for 1990 and 1991; (3) whether
petitioners are liable for additions to tax for failing to make
estimated Federal income tax payments for 1990 and 1991; (4)
whether petitioners are liable for accuracy-related penalties for
1993 and 1994; and (5) whether petitioners engaged in behavior
that warrants the imposition of a penalty pursuant to section
6673(a).
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
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Last modified: May 25, 2011