Cristeen B. Comey - Page 2




                                        - 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