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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.
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Last modified: May 25, 2011