- 2 - OPINION OF THE SPECIAL TRIAL JUDGE DEAN, Special Trial Judge: This case is before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, filed pursuant to Rule 40. The motion also seeks an award of a penalty against petitioners under section 6673. Petitioners resided in Fort Worth, Texas, at the time the petition in this case was filed. Respondent's Notices of Deficiency On September 29, 1997, respondent mailed petitioners respective notices of deficiency determining the following deficiencies and additions to petitioners' Federal income taxes: Petitioner Gregory Stewart Malone Taxable Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1992 $20,029 $5,007 $882 1993 15,207 3,802 637 1994 21,076 5,269 1,086 1995 20,723 5,181 1,131 Petitioner Pamela Joyce Malone Taxable Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1992 $11,744 $2,936 $512 1993 7,241 1,818 303 1994 12,141 3,035 626 1995 10,030 2,508 548 The deficiencies in income tax determined by respondent are based on the determination that petitioners receivedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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