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MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
respondent's motions for entry of decision filed in Estate of
Lorenz v. Commissioner, docket No. 12138-96, and in Comet
Printing, Inc. v. Commissioner, docket No. 12140-96. Petitioners
filed objections to respondent's motions, and respondent filed
replies to petitioners' responses. No party requested a hearing,
and we conclude that none is necessary.
When these cases were called for trial, counsel for the
parties reported that they had reached a basis of settlement,
which they stated for the record. They now ask the Court to
construe the basis of settlement on two points:
1. Whether the fraud penalties for Elizabeth Lorenz and
for the Estate of Kevin J. Lorenz for 1989 and 1990 should both
be computed based on the entire deficiency, as respondent
contends, or on one-half of the deficiency, as petitioners
contend. We hold that they should both be computed based on the
entire deficiency.
2. Whether the depreciation deductions for Comet Printing,
Inc., should be increased by $19,432 for 1989 and $22,863 for
1990 from the amounts determined by respondent in the notice of
deficiency. We hold that they should not.
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