Estate of Frank Johnson - Page 5




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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  These five cases have been consolidated for           
          trial, briefing, and opinion.  Respondent, by two notices of                
          deficiency dated April 4, 1997, determined deficiencies,                    
          additions, and penalties with respect to Federal income taxes               
          owed by petitioners the Estate of Frank Johnson, Larry T.                   
          Johnson, Personal Representative, and the Estate of Katherine               
          Johnson, Larry T. Johnson, Personal Representative (hereinafter             
          referred to as petitioners).  Such deficiencies, additions, and             
          penalties are on account of returns of income tax made by Frank             
          and Katherine Johnson (sometimes decedents), and are as follows:            
                                Additions to Tax and Penalties                       
                             Sec.    Sec.     Sec.      Sec.                         
          Docket                       6653    6653     6653      6653     Sec.   Sec.
          No.    Year  Deficiency  (b)(1)  (b)(2)  (b)(1)(A) (b)(1)(B)  6663   6661   
          14518-97  1983   $37,058   $18,529    1         -         -        -    $9,265
          14519-97  1984    39,763    19,882    2         -         -        -     9,941
          1985    51,732    25,866    3         -         -        -    12,933        
          1986    43,537       -      -      $32,653      4        -    10,884        
          1987    67,496       -      -       50,622      5        -    16,874        
          1988    74,169    55,627    -         -         -        -    18,542        
          1989    73,600       -      -         -         -    $55,200     -          
          1990    96,275       -      -         -         -     72,206     -          
          150 percent of the interest due on $37,058.                                 
          250 percent of the interest due on $39,763.                                 
          350 percent of the interest due on $51,732.                                 
          450 percent of the interest due on $43,537.                                 
          550 percent of the interest due on $67,496.                                 
               By notices of liability dated April 4, 1997, respondent                
          asserted transferee liability against the following petitioners             
          relating to the above deficiencies, additions to tax, and                   








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