- 4 -
David and Sara 1991 363,170 48,775 50,770
Deitsch 1992 790,380 130,075 60,296
1993 30,004 153 11,972
1994 314,102 37,868 49,904
Respondent further determined that if the 40-percent section
6662(h) accuracy-related penalty were deemed inapplicable,
amounts upon which it had been computed were subject, in the
alternative, to the 20-percent section 6662(a) penalty.
Respondent has since conceded the section 6662(h) penalty.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure. Dollar amounts are rounded to the
nearest dollar.
These cases have been consolidated for purposes of trial,
briefing, and opinion. Hereinafter and unless directed toward
the collective position of all petitioning litigants, references
to petitioners shall be to the individual petitioners, with the
exception of B. Mayer and Ella Zeiler. The Zeilers’
circumstances involve different considerations, and counsel
represented at trial that their case has been entirely settled
through stipulation. We shall discuss facts pertaining to the
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