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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: This case is before
the Court on respondent's Motion for Partial Summary Judgment
filed pursuant to Rule 121. As discussed in greater detail
below, we will grant respondent's motion.
Background
Respondent determined deficiencies in and additions to
petitioners' Federal income taxes for the years and in the
amounts as follows:
Additions and Penalties
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6663
1987 $9,921 --- $7,441 50% of interest --- ---
on underpayment
due to fraud
1988 36,492 --- --- --- $27,369 ---
1989 13,488 $3,364 --- --- --- $10,116
1990 28,619 7,083 --- --- --- 21,464
1991 55,391 13,749 --- --- --- 41,543
1992 40,029 7,951 --- --- --- 30,022
1993 87,539 --- --- --- --- 65,654
Petitioners invoked the Court's jurisdiction by filing a
timely petition for redetermination. At the time the petition
was filed, petitioners resided in Houston, Texas.
2 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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