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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined deficiencies, additions
to tax, and accuracy-related penalties for 1991, 1992, and 1993
with respect to petitioners' Federal income taxes as follows:
Addition to tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $23,617 $5,345 $4,723
1992 28,454 6,597 5,691
1993 32,748 1,566 6,550
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. All dollar amounts are rounded to the
nearest dollar.
After concessions by both parties, the remaining issues for
decision are: (1) Whether petitioners are liable for the
additions to tax under section 6651(a)(1) for failure to timely
file their 1991, 1992, and 1993 Federal income tax returns; and
(2) whether petitioners are liable for the accuracy-related
penalty under section 6662(a).
FINDINGS OF FACT
At the time the petition was filed, petitioners resided in
Los Angeles, California. During the years in issue, petitioner
Franklin Terrell was a general contractor engaged in the
construction business.
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