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MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: Respondent determined that
petitioners in these consolidated cases are liable for
deficiencies in Federal income tax as follows:
Docket No. Year Amount
19401-98 1996 $22,389
2358-99 1995 2,679
2743-99 1996 3,659
Respondent also determined that petitioners in docket Nos.
19401-98 and 2743-99 were liable for the accuracy-related penalty
under section 6662(a)2 but has now conceded that issue. After
other concessions which will be detailed hereinafter, the issue
to be resolved in these consolidated cases is whether part of the
income earned by petitioner husbands from their trucking activity
can be allocated to a leasing activity. If we hold for
petitioners on this issue, we must then decide whether
petitioners’ method of allocation or some other method is
correct.
Some of the facts have been stipulated and are so found.
The several stipulations of fact and attached exhibits are
incorporated herein by reference. At the time of the filing of
the petitions herein, all petitioners resided in the State of
California.
2 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue.
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Last modified: May 25, 2011