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MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in income
tax, additions to tax, and penalties in these consolidated1 cases
as follows:
Patrick S. and Donna J. Elliott
Docket No. 19425-98
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1992 $8,787 $2,179 $1,757
1993 11,681 --- 2,336
1994 32,325 --- 6,465
1995 4,316 --- 863
Larry S. and Julia F. Elliott
Docket No. 19433-98
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1992 $12,330 $2,583 $2,466
1993 16,433 4,052 3,289
1994 48,631 10,376 9,726
1995 10,616 489 2,123
Numerous issues have been settled by the parties, leaving
the following issue for our consideration: whether the notices
of deficiency sufficiently informed petitioners that they were
not being allowed to offset deductions against compensation on
their Forms 2106, Employee Business Expenses.2
1 These cases have been consolidated for purposes of trial,
briefing, and opinion.
2 Petitioners do not attempt to substantiate the expenses in
question. Instead, they ask us to find they are allowable as
claimed on the basis of petitioners’ procedural argument.
(continued...)
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