- 2 -
are not reviewable by any other court, and this opinion should
not be cited as authority.
Respondent determined the following additions to tax with
respect to petitioners’ Federal income taxes:
Dolores J. Myers, docket No. 15862-99S
Sec. Sec. Sec. Sec.
Year 6653(a)(1) 6653(a)(2) 6653(a)(1)(A) 6653(a)(1)(B)
1985 $15.50 50 percent -- -–
of interest
due on $310
1986 –- –- $24.60 50 percent
of interest
due on $492
Estate of James T. Myers, Deceased & Dolores J. Myers, Surviving
Wife, docket No. 16247-99S
Sec. Sec.
Year 6653(a)(1) 6653(a)(2)
1982 $185.00 50 percent
of interest
due on $3,700
1983 20.80 50 percent
of interest
due on $416
These cases were consolidated for trial, briefing, and opinion
pursuant to Rule 141(a) because they present common issues of
fact and law.
1(...continued)
indicated, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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