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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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