Marty M. Morin and Marilee D. Morin - Page 2




                                        - 2 -                                         

               Additions to Tax                                                       
          Year     Deficiency      Sec. 6651(a)      Sec. 6654                        
          1993       $3,545             --               --                           
          1994       11,645           $2,911            $601                          
          1995        1,624              406              87                          
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               After concessions,1 the issues for decision are:  (1)                  
          Whether petitioners are liable for the deficiencies determined by           
          respondent, (2) whether Marty M. Morin (Mr. Morin) is liable for            
          an addition to tax for failing to file a Federal income tax                 
          return for 1993, (3) whether petitioners are liable for additions           
          to tax for failing to file Federal income tax returns for 1994              
          and 1995, (4) whether Mr. Morin is liable for an addition to tax            
          for failing to make estimated Federal income tax payments for               
          1993, (5) whether petitioners are liable for additions to tax for           
          failing to make estimated Federal income tax payments for 1994              
          and 1995, and (6) whether petitioners engaged in behavior                   
          warranting the imposition of a penalty pursuant to section                  
          6673(a).                                                                    



               1  Respondent concedes that petitioners did not receive any            
          gain from the sale of real estate in 1994.                                  






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