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Jeremy L. McPherson, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos pursuant to the provisions of
section 7443A(b)(5). Unless otherwise indicated, section
references are to the Internal Revenue Code as amended, and 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
PANUTHOS, Chief Special Trial Judge: Respondent determined
deficiencies in petitioners’ Federal income tax for the taxable
year 1995, additions to tax, and penalties as follows:
Addition to Tax Penalty
Docket No. Deficiency Sec. 6651(a)(1) Sec. 6662(a)
18510-99 $196,211 $9,780.75 $39,242.20
1366-00 53,503 2,675.00 10,701.00
1367-00 22,951 1,148.00 4,590.00
1368-00 9,105 455.00 1,821.00
1369-00 574 29.00 115.00
1370-00 114,727 5,736.00 22,945.00
1371-00 4,453 223.00 891.00
Background
These cases are before the Court on respondent’s motions to
dismiss for failure to state a claim and to impose a penalty
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