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MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: In these consolidated cases, respondent
determined the following deficiencies, additions to tax, and
penalties in petitioners’ Federal income taxes:
Docket No. 24410-95
Lucian T. Baldwin III and Teresa M. Baldwin:
Accuracy-
Additions to tax related penalty
Year Deficiency Sec. 6653(a)(1) Sec. 6661 Sec. 6662(a)
1988 $418,914 $20,946 $104,729 ---
1989 441,563 — --- $88,313
Docket No. 18739-95
Lucian T. Baldwin III:
Accuracy-
related penalty
Year Deficiency Sec. 6662(a)
1990 $660,180 $132,036
1991 627,605 125,521
1992 331,541 66,308
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Monetary amounts are
rounded to the nearest dollar.
After concessions,1 the issues for decision are:
1Respondent has conceded that petitioner Teresa M. Baldwin
(Mrs. Baldwin) qualifies for relief from joint liability under
sec. 6015. Other assignments of error raised in the petitions
and not addressed in the stipulations of settled issues or on
brief are deemed conceded. See Rule 151(e)(4) and (5); Petzoldt
v. Commissioner, 92 T.C. 661, 683 (1989); Money v. Commissioner,
(continued...)
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