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separately petitioned the Court to redetermine respondent's
determinations as to their 1993, 1994, and 1995 taxable years.
Respondent determined that Shane Michael was liable for accuracy-
related penalties under section 6662(a) of $2,091, $3,379, and
$2,437, respectively, and that it was liable for a $1,704
addition to its 1994 tax under section 6651(a)(1). Respondent
determined that the Shanes were liable for accuracy-related
penalties under section 6662(a) of $5,653, $6,244, and $8,043,
respectively, and that they were liable for a $1,557 addition to
their 1994 tax under section 6651(a)(1).
Respondent concedes that none of petitioners are liable for
the additions to tax. Thus, we are left to decide whether Shane
Michael and the Shanes are liable for the accuracy-related
penalties. We hold they are not. Unless otherwise stated,
section references are to the Internal Revenue Code in effect for
the years in issue. Rule references are to the Tax Court Rules
of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulated
facts and the exhibits submitted therewith are incorporated
herein by this reference. When the Court filed the respective
petitions, Shane Michael's legal address was in San Francisco,
California, and the Shanes resided in San Mateo, California.
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