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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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