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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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Last modified: May 25, 2011