- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011