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MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notices dated December 22, 1995, and March
12, 1996, respectively, respondent determined the following
deficiencies in and additions to petitioners' Federal income
taxes:
Larry Whittington, docket No. 5208-96
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(1)(A) Sec. 6653(a)(2) Sec. 6653(a)(1)(B) Sec. 6661
1985 $54,635 $2,732 -- 1 -- $13,659
1986 45,307 -- $2,265 -- 1 11,327
1987 48,182 -- 2,409 -- 1 12,046
1 50 percent of the statutory interest on the deficiency.
Ray and Glynda Whittington, docket No. 11955-96
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(1)(A) Sec. 6653(a)(2) Sec. 6653(a)(1)(B) Sec. 6661
1985 $30,740 $1,537 -- 1 -- $6,550
1986 27,434 -- $1,372 -- 1 4,663
1987 41,243 -- 2,062 -- 1 9,079
1 50 percent of the statutory interest on the deficiency.
Unless otherwise indicated, all section references are to
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. After concessions, the issues for decision are
whether petitioners are: (1) Entitled to exclude parsonage
allowances from income; (2) subject to tax on certain income;
(3) entitled to deduct certain charitable contributions;
(4) liable for additions to tax for negligence; and (5) liable
for additions to tax for substantial understatements of tax.
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Last modified: May 25, 2011