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MEMORANDUM OPINION
WELLS, Judge: Respondent determined a deficiency in
petitioners'1 1991 Federal income tax in the amount of $3,506,517
and a section 6662 penalty of $701,303.
Unless otherwise indicated, 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.
1 The notice of deficiency in the instant case was sent to
William T. Rogers and Gayle M. Rogers. William T. Rogers died
during 1998, after the briefs were submitted. Accordingly, the
caption of the instant case was amended to substitute for William
T. Rogers the Estate of William T. Rogers, Gayle M. Rogers,
Personal Representative. For convenience, we hereinafter refer
to petitioner Gayle M. Rogers as petitioner, William T. Rogers as
Mr. Rogers, petitioner and Mr. Rogers as the Rogerses, and
petitioner and the Estate of William T. Rogers, Gayle M. Rogers,
Personal Representative, as petitioners.
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