- 2 -
71, I.R.C., and are therefore deductible by H and
includable in the gross income of W for taxable year
1992. Secs. 61(a)(8), 71(a), and 215(a), I.R.C.
W. James Slaughter, for petitioner Norman D. Peterson.
Randall R. Wittman, for petitioner Marta E. Peterson.
Linas N. Udrys, for respondent.
MEMORANDUM OPINION
NIMS, Judge: In these consolidated cases, respondent
determined the following deficiencies and accuracy-related
penalty with respect to the Federal income taxes of petitioners
Norman D. Peterson (Norman) and Marta E. Peterson (Marta):
Docket No. 12074-96
(Norman D. Peterson)
Year Deficiency
1992 $15,161
Docket No. 17347-96
(Marta E. Peterson)
Penalty
Year Deficiency Sec. 6662(a)
1992 $16,030 $3,206
All section references are to sections of the Internal
Revenue Code in effect for the year in issue, unless otherwise
indicated. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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