- 2 - Federal income tax for 1991 and 1992:1 Sec. 6662 Sec. 6662 Substantial Negligence or Understatement Disregard Year Deficiency Penalty Penalty 1991 $25,679 $5,136 -- 1992 281 -– $56 Respondent also determined the following deficiencies in and additions to the 1991 and 1992 Federal income tax of Mrs. Comey’s son, petitioner David L. Comey: Sec. 6662 Sec. 6651(a)(1) Negligence or Failure to File Disregard Year Deficiency Addition Penalty 1991 $7,834 $1,889 $1,567 1992 118,430 23,338 23,686 In the notice to Mrs. Comey, respondent determined that the gain realized on the sale of certain mutual fund shares in 1991 was the income of Mrs. Comey. Similarly, in the notice to Mr. Comey, respondent determined that the interest, dividends, and capital gains paid or realized in 1991 and 1992 with respect to the shares of certain publicly traded corporations (and a debenture and bank account) were the income of Mr. Comey. 1 All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise specified.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011