Estate of Kevin J. Lorenz, Deceased, Elizabeth J. Lorenz, Personal Representative and Elizabeth J. Lorenz - Page 7

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                        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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