- 3 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. Background A. Petitioners Elizabeth J. Lorenz (Mrs. Lorenz) lived in Spokane, Washington, when she filed the petition on behalf of herself and the Estate of Kevin J. Lorenz (Mr. Lorenz). Mr. Lorenz was Mrs. Lorenz's husband when he died. The principal place of business of Comet Printing, Inc. (Comet), was in Spokane, Washington, when it filed its petition. Mrs. Lorenz owned Comet when it filed its petition. B. Respondent's Determinations Respondent determined a deficiency in income tax for Mr. and Mrs. Lorenz of $31,880 for 1989 and $60,258 for 1990, and determined that they are liable for a fraud penalty of $23,910 for 1989 and $45,194 for 1990 under section 6663. Respondent determined a deficiency in income tax for Comet of $34,710 for 1989 and $64,915 for 1990, and determined that Comet is liable for a fraud penalty of $26,032 for 1989 and $48,686 for 1990 under section 6663. C. The Settlement Charles Hammer (Mr. Hammer) represented petitioners and Lisa Oshiro (Ms. Oshiro) represented respondent when the cases werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011