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Additions to Tax Penalty
Petitioner Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6662(a)
MatrixInfoSys 1995$23,789 –- -- $4,758
Trust 1996 23,666 -- -- 4,733
Andy Hromiko 1994 $20,340 $5,085 $1,055 --
1995 20,176 5,044 1,094 –-
1996 19,447 4,862 1,035 –-
1997 18,366 4,592 983 –-
Unless otherwise stated, 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.
We must resolve a basic dispute between the parties:
whether certain payments made to a trust, MatrixInfoSys (the
trust), on account of services performed by Andy Hromiko
(petitioner) should have been returned as income on petitioner’s
individual tax return. Because respondent adopted “whipsaw”
positions in making the determinations against petitioner and the
trust, respondent will concede the tax liabilities determined
against the trust if the Court concludes that the payments made
to the trust are properly taxable to petitioner.
FINDINGS OF FACT
At the time of the filing of the trust’s petition, the
trust’s address was in Roseville, California. Similarly, at the
time petitioner filed his petition, he resided in Roseville,
California. Before setting out our specific factual
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Last modified: May 25, 2011