- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011