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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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Last modified: May 25, 2011