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Gary D. Kallevang, Wilton A. Baker, Kim A. Palmerino, and
William H. Quealy, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: These cases were assigned to Chief Special
Trial Judge Peter J. Panuthos pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: By timely notices of
deficiency, respondent determined that petitioners in these
consolidated cases are liable for deficiencies, additions to tax,
and penalties as follows:
Leema Enterprises, Inc., docket No. 39476-85
Additions to Tax
Year Deficiency Sec. 6653(a)(1)
6/30/80 $432,667 $21,633
6/30/81 1,100,399 55,020
Leema Enterprises, Inc., docket No. 4797-86
Addition to Tax
Year Deficiency Sec. 6653(a)(1)
6/30/82 $785,688 $39,284
2 All section references are to the Internal Revenue
Code, unless otherwise indicated. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011