- 2 - Richard R. and Paula A. Pelham Docket No. 18687-99 Penalty Year Deficiency Sec. 6662(a) 1996 $4,761 $952 1997 11,050 2,210 RRP Trust, Richard R. Pelham, Trustee Docket No. 18688-99 Penalty Year Deficiency Sec. 6662(a) 1996 $12,297 $2,459 1997 36,558 7,312 Unless otherwise indicated, 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. After concessions by the parties, the issue remaining for decision is whether petitioner RRP Trust (the trust) should be disregarded for Federal income tax purposes and the income and expense from the business operations of Lake Lock & Key attributed to petitioners Richard R. Pelham and Paula A. Pelham (the Pelhams). FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Richard R. Pelham (Richard Pelham) and Paula A. Pelham (Paula Pelham), husband and wife, resided in Humble, Texas, atPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011