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Maurice H. Sochia
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1992 $12,879.15 $3,158.16 $537.83
1993 7,955.00 1,941.63 324.53
1994 8,227.20 1,985.93 410.59
Beatrice M. Sochia
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1992 $12,879.15 $3,158.16 $549.77
1993 7,955.00 1,941.63 324.53
1994 8,227.20 1,985.93 410.59
We must decide the following issues: (1) Whether
petitioners had unreported income during the years in issue; (2)
whether petitioners are liable for the addition to tax for
failure to timely file income tax returns under section 6651(a)
for each of the years in issue; (3) whether petitioners are
liable for the addition to tax for failure to pay estimated
Federal income tax under section 6654(a) for each of the years in
issue; and (4) whether petitioners are liable for a penalty under
section 6673.
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
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Last modified: May 25, 2011