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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, at
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Last modified: May 25, 2011