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moved for penalties on account of delay and for other
reasons, under sec. 6673(a)(1), I.R.C. Trusts P3, P4,
and P5 concede all adjustments and the accuracy-related
penalty. R concedes items of P3, P4, and P5 taxed to
either P1 or P2 and certain other items of P1 and P2.
1. Held: Deficiencies and accuracy-related
penalty with respect to P3, P4, and P5 sustained,
subject to concession by R.
2. Held, further, P6 has failed to establish that
there is a proper party before the Court; we shall
dismiss with respect to P6 for lack of jurisdiction.
3. Held, further, P1 understated gross income by
$166,042 on account of gross receipts of P3
attributable to them under assignment of income
doctrine.
4. Held, further, P1 failed to substantiate
depreciation deduction of $19,866 apportioned to them
by P4.
5. Held, further, P1 are liable for accuracy-
related penalties under sec. 6662(a), I.R.C.
6. Held, further, P1 are liable for a penalty
under sec. 6673(a)(1), I.R.C.
7. Held, further, P2 omitted from gross income
interest of $425, bank deposits of $33,890, and income
from services of $2,470.
8. Held, further, P2 are liable for accuracy-
related penalties under secs. 6662(a) and 6673(a)(1),
I.R.C.
9. Held, further, P2 are liable for a penalty
under sec. 6673(a)(1), I.R.C.
Noel W. Spaid, for petitioners.
Jeremy L. McPherson and Neal O. Abreu, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: These consolidated cases involve
determinations by respondent of deficiencies in, and penalties
with respect to, the Federal income tax liabilities of the
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