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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.
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Last modified: May 25, 2011