- 2 - 1. Held: Trust income is attributed to H and W for the reasons stated by R. 2. Held, further, H and W omitted nontrust income and overstated deductions. 3. Held, further, H and W are liable for the accuracy-related penalty under sec. 6662(a), I.R.C. 4. Held, further, R’s motion to dismiss for lack of jurisdiction will be granted. 5. Held, further, Ps bear the burden of proof. Robert Hogue, pro se in docket No. 10400-99. Michael T. Carey, pro se in docket No. 10502-99. Jeremy L. McPherson, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: These consolidated cases involve determinations by respondent of deficiencies in, and penalties with respect to, the Federal income tax liabilities of the following taxpayers, for the 1995 taxable (calendar) year of each, in the following amounts: Penalty Taxpayer(s) Deficiency Sec. 6662(a) Res. Mgmt. Svcs. Tr. $65,834 $13,167 Michael & Leone Carey 272,707 54,541 These cases are related in that, under various theories, respondent believes that there is an identity between Residential Management Services Trust (the trust) and Michael and Leone Carey (the Careys or, individually, Michael or Leone). Among otherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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