- 2 - Accuracy-Related Penalty Taxpayer Year Deficiency Sec. 6662(a) Jean S. Ballantyne 1993 $4,998 -- Estate of Melvin W. 1994 10,735 –- Ballantyne, Jean S. Ballantyne, Surviving Spouse Estate of Melvin W. 1994 172,035 –- Ballantyne, Jean S. Ballantyne, Executrix Estate of Melvin W. 1995 14,562 $2,912 Ballantyne, Jean S. Ballantyne, Executrix Respondent determined deficiencies in income tax and penalties in docket No. 16346-99 for Russell E. Ballantyne and Clarice Ballantyne as follows: Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1993 $77,672 -- 1994 325,761 $63,646.40 1995 47,381 9,476.20 In order to protect the Government from a potential whipsaw, respondent has taken inconsistent positions in these dockets.1 After concessions, the issues for decision are: (1) The proper allocation between the Estate of Melvin W. Ballantyne and petitioner Russell E. Ballantyne of gain from the sale of grain in 1994; (2) whether petitioner Russell E. Ballantyne had additional gain in 1994 in the amount of $751,988 which should 1These cases were consolidated for purposes of trial, briefing, and opinion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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