- 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.
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