Estate of Frank Johnson - Page 7




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               (6) whether decedents may increase their self-employment tax           
          deduction for 1990,                                                         
               (7) whether decedents are entitled to a married couples                
          deduction for each of the years 1983, 1984, 1985, and 1986,                 
               (8) whether decedents are liable for the additions to tax or           
          penalties for fraud under sections 6653(b) or 6663, as                      
          applicable, for each of the years in issue,                                 
               (9) whether decedents are liable for additions to tax under            
          section 6661 for substantial understatement of income for each of           
          the years 1983 through 1988,                                                
               (10) whether petitioner Larry Johnson is liable as a                   
          transferee of Frank and Katherine Johnson for $861,668,                     
               (11) whether petitioner Sylvia Johnson is liable as a                  
          transferee of Frank and Katherine Johnson for $229,685,                     
               (12) whether petitioner Ronnie Johnson is liable as a                  
          transferee of Frank and Katherine Johnson for $766,003.                     
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  For convenience, monetary amounts have been rounded             
          to the nearest dollar.  References to cash include cash                     
          equivalents such as cashier’s checks and money orders.                      










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