Alfred L. and Renee E. Fields - Page 2




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          petitioners’ Federal income taxes, additions to tax, and penalties,          
          as follows:                                                                  
          Alfred L. and Renee E. Fields, Docket No. 22011-97:                          
                              Additions to tax     Accuracy-Related Penalty            
          Year  Deficiency    Sec. 6651(a)(1)      Sec. 6662(a)                        
          1993   $10,913      $2,188                    $2,183                         
          1994    18,871      4,718                     3,774                          
          Frank H. and Irma E. Bullock, Docket No. 22012-97:                           
                              Additions to tax     Accuracy-Related Penalty            
          Year  Deficiency    Sec. 6651(a)(1)      Sec. 6662(a)                        
          1993    $12,510          ---                  $2,502                         
          1994     21,422          $967                 4,284                          

          Leroy and Mattrude P. Sharpe, Docket No. 22013-97:                           
                                   Accuracy-Related Penalty                            
          Year      Deficiency     Sec. 6662(a)                                        
          1993      $8,337              $1,667                                         
          1994      18,467              3,693                                          

          Esker L. Peacock, Docket No. 22014-97:                                       
                                   Accuracy-Related Penalty                            
          Year      Deficiency     Sec. 6662(a)                                        
          1993      $11,103             $2,221                                         
          1994      19,403              3,881                                          
               After concessions, the issues for decision are: (1) Whether             
          petitioners had unreported income during the years under                     
          consideration as determined by respondent; (2) whether petitioners           
          in docket No. 22012-97 (the Bullocks) are entitled to losses                 
          claimed in connection with Frank Bullock’s van pool activity; (3)            





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