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OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: Respondent determined
deficiencies in petitioners’ Federal income taxes and negligence
penalties under section 6662(a) as follows:2
Year Deficiency Sec. 6662(a)
1990 $51,417 $10,283
1991 50,542 10,108
1993 36,903 7,381
After the notice of deficiency was issued, respondent
acknowledged that the deficiencies and penalties were overstated
for 1991 and 1993. Respondent asserts the deficiencies and
penalties for 1991 and 1993 are as follows:
Year Deficiency Sec. 6662(a)
1991 $48,307 $9,661
1993 30,072 6,014
2 At the time of filing the petition, petitioner
requested, and the Court granted, a request for small tax case
status pursuant to sec. 7463. The Court notes that the petition
reflects for each taxable year an amount in dispute including
penalties of less than $50,000. After commencement of trial, it
became apparent that for each of the taxable years 1990 and 1991,
the deficiencies and penalties placed in dispute exceeded the
limit ($50,000) permitted under sec. 7463. Accordingly, the
small tax case status was discontinued pursuant to sec. 7463(d)
and Rule 173. By order dated Apr. 18, 2000, the caption was
amended by deleting the letter “S” from the docket number.
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Last modified: May 25, 2011