James D. and Rita K. Snyder - Page 2




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               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.                                 






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