Estate of Haines B. Gaffner - Page 2




                                        - 2 -                                         
                             Haines B. Gaffner, Deceased                              
                    Addition to Tax Under                                             
           Year   Deficiency  Sec. 6651(a)(1)1 Sec.6651(a)(2) Sec. 6654               
          1992   $75,428.00     $15,797.25          –-       $3,289.81                
          1993    94,418.00      18,622.00          --        3,028.21                
          1994    99,382.00      19,624.25          --        3,952.91                
          1995   110,823.00      22,236.50          --        4,691.07                
          1996   146,782.00      31,279.73          *         7,353.55                
               *The addition to tax under sec. 6651(a)(2) is calculated as .5         
          percent of the amount shown as tax in the tax return if the failure         
          to pay such tax on or before the date prescribed for payment of such        
          tax is not for more than 1 month, with an additional .5 percent for         
          each additional month or fraction thereof during which such failure         
          continues, not exceeding 25 percent in the aggregate.                       
                                 Mary Ellen Gaffner                                   
                    Addition to Tax Under                                             
           Year   Deficiency  Sec. 6651(a)(1)  Sec. 6651(a)(2) Sec. 6654              
          1992   $38,043.00     $6,451.00           –-        $1,659.25               
          1993    44,705.00      6,194.00           –-           945.31               
          1994    48,761.00      6,968.75           –-         1,326.05               
          1995    49,707.00      6,957.75           –-         1,377.26               
          1996   190,063.00     41,017.73           *          9,657.13               
               *The addition to tax under sec. 6651(a)(2) is calculated as .5         
          percent of the amount shown as tax in the tax return if the failure         
          to pay such tax on or before the date prescribed for payment of such        
          tax is not for more than 1 month, with an additional .5 percent for         
          each additional month or fraction thereof during which such failure         
          continues, not exceeding 25 percent in the aggregate.                       
                                                                                     
               The issues remaining for decision are:                                 
               1.  Do petitioners2 have rental income for 1996 in an amount           
          that is less than the amount determined by respondent?  We hold             
          that they do not.                                                           


               1All section references are to the Internal Revenue Code               
          (Code) in effect for the years at issue.  All Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           
               2We shall refer collectively to the petitioner in each of              
          these consolidated cases as petitioners.                                    




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