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Nick Hay, for petitioner.
James S. Stanis, for respondent.
OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to Rules 180, 181, and 183.
All Rule references are to the Tax Court Rules of Practice and
Procedure. The Court agrees with and adopts the opinion of the
Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: Respondent determined
deficiencies in petitioner’s 1993 and 1994 Federal excise taxes
under section 4975(a)1 of $800 and $1,303, respectively.
Respondent also determined additions to tax under section
6651(a)(1) for 1993 and 1994 of $200 and $326, respectively. The
issues are (1) whether petitioner is a disqualified person under
section 4975(e), and, if so, (2) whether petitioner is liable for
the section 6651(a)(1) additions to tax.
At the time the petition was filed petitioner’s principal
place of business was located in Arden Hills, Minnesota.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue.
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Last modified: May 25, 2011