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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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