Mark D. Pridgen and Kay D. Pridgen - Page 2




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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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