- 2 - James D. and Rita K. Snyder, pro se. Dale A. Suzi, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notice of deficiency dated March 31, 1999 (the notice), respondent determined deficiencies in, and an addition and penalties with respect to, petitioners’ 1992 through 1995 Federal income taxes, as follows: Sec. 6651(a) Sec. 6662(a) Year Deficiency Addition to Tax Penalty 1992 $70,215 -- $14,043 1993 90,783 $4,547 18,157 1994 87,301 -- 17,460 1995 120,866 -- 24,173 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. For convenience, monetary amounts have been rounded to the nearest dollar amount. At the conclusion of the trial in this case, respondent moved that the Court impose penalties under section 6673(a)(1), which provides penalties for procedures instituted primarily for delay and for other reasons. We took that motion under advisement. Respondent has conceded the addition to tax for 1993, determined under section 6651(a) for failure to file a return on time. We accept that concession.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011