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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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