Gregory Stewart Malone and Pamela Joyce Malone - Page 2

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                               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 received                                        





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