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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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Last modified: May 25, 2011