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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 were
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Last modified: May 25, 2011