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MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies in and
additions to tax and penalties with respect to petitioners’
Federal income taxes as follows:
Bob J. & Ernestene Sams
Docket No. 16023-99
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1994 $16,793 $4,133 $3,358.60
1995 35,955 – 7,191.00
Carter Bonding Company, Inc.
Docket No. 16024-99
Year Deficiency Sec. 6651(a)(1) Sec. 6655(a) Sec. 6662(a)
1994 $11,095 $555 – $2,219
1995 23,386 5,847 $610 –
Sherri Lynn Sullivan
Docket No. 18739-99
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $11,835 $2,959 $517
1993 4,740 1,185 197
1994 26,928 6,732 1,387
1995 44,771 11,193 2,443
For reasons discussed below, the only issue remaining in
these cases is whether the gross income of petitioner Carter
Bonding Company, Inc. (Carter Bonding), should be determined by
reference to the fees charged for bail bonds written during the
years in issue, as reported to the Oklahoma Insurance Commission,
or whether Carter Bonding’s gross income was a lesser amount as
claimed by petitioners. Unless otherwise indicated, all section
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Last modified: May 25, 2011