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Penalty
Year Deficiency Sec. 6662(a)
1990 $129,169 $25,834
1991 232,416 46,483
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect during the years in
issue. Respondent also determined the following
deficiencies in, addition to, and penalties with respect
to the Federal income tax of petitioners Dewey and Francine
Gaskins, in the case at docket No. 2075-97:
Penalty Addition to Tax
Year Deficiency Sec. 6662(a) Sec. 6651(a)(1)
1990 $131,723 $26,345 --
1991 240,086 48,017 $12,004
References in this opinion to "petitioners" are references
to Mr. Pridgen and Mr. Gaskins. Petitioners and their
wives resided in the State of North Carolina at the time
the subject petitions were filed.
The above-captioned cases were consolidated for trial,
briefing, and opinion by an order of the Court issued
pursuant to Rule 141, Tax Court Rules of Practice and
Procedure. In this opinion, all Rule references are
to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011