- 7 - MR. HAMMER: That's correct, Your Honor. We're in agreement -- full agreement on both 1989 and 1990 as to the corporation and the individual. The Court gave the parties 45 days to prepare and file decision documents. D. Respondent's Proposed Decisions Respondent sent proposed decisions to petitioners which stated that Mrs. Lorenz and the estate of Mr. Lorenz have a deficiency in Federal income tax of $14,720 for 1989 and $54,630 for 1990. The proposed decisions also stated that Mrs. Lorenz is liable for the fraud penalty at the reduced rate of 20 percent and the estate of Mr. Lorenz is liable for the fraud penalty at the rate of 75 percent, as follows: Joint Liability at 20-Percent Rate Penalty Under Year Sec. 6663 1989 $2,944 1990 10,926 Additional Amount Due From Estate of Kevin J. Lorenz, Deceased, at 75-Percent Rate Penalty Under Year Sec. 6663 1989 $8,096 1990 30,046 Petitioners' accountant told respondent's counsel that he thought respondent had calculated the fraud penalty for Mrs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011