Walter O. Bowen and Susan M. Bowen, et al. - Page 2




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          penalties with respect to petitioners’ Federal income tax returns           
          for the taxable year 1995:2                                                 
          Walter O. Bowen & Susan M. Bowen, docket No. 13714-99                       
                    Deficiency            Sec. 6662(a) penalty                        
                    $205,316                 $41,063                                  
          Bow N Arrow Family Trust, docket No. 13723-99                               
                    Deficiency            Sec. 6662(a) penalty                        
                    $98,219                  $19,644                                  
          Naturally Right Co., a.k.a. Naturally Right Company, docket No.             
          13724-99                                                                    
                    Deficiency            Sec. 6662(a) penalty                        
                    $98,060                  $19,612                                  
               Petitioners in each docket filed separate petitions                    
          contesting respondent’s determinations.  These cases were                   
          consolidated for trial, briefing, and opinion pursuant to Rule              
          141(a) because they present common issues of fact and law.  At              
          trial, respondent conceded the deficiencies and penalties in                
          docket Nos. 13723-99 and 13724-99, leaving only the issues in               
          docket No. 13714-99 for trial.  In docket No. 13714-99, Walter O.           
          Bowen and Susan M. Bowen (hereinafter petitioners) conceded that            
          they were liable for a deficiency to be calculated by using a               
          formula agreed to by the parties and that the exact amount would            
          be determined in accordance with Rule 155.                                  




               2All section references are to the Internal Revenue Code in            
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  




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