- 5 - 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, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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