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MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: In these consolidated cases, respondent
determined deficiencies in petitioners’ Federal income tax and
additions to tax and/or penalties as follow:
Docket Nos. 9294-95 and 3284-96
Petitioner Cordes Finance Corp.:
Penalties
Year Deficiency sec. 6662(a)2 sec. 6663
1991 $606,863 $121,373 $9,773
1992 686,695 131,784 20,832
1993 743,902 145,200 13,428
Docket Nos. 20254-94 and 3305-96
Petitioner June Cordes:3
Additions to tax
Year Deficiency sec. 6651(a)(1) sec. 6654
1989 $135,298 $33,825 $232
1990 134,608 33,652 8,863
1991 368,551 92,138 21,201
Docket No. 4182-96
Petitioners Edmund J. & June J. Cordes:
Penalties
Year Deficiency sec. 6662(a)
1992 $17,281 $3,456
1993 98,957 19,791
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure. Monetary amounts have been rounded to
the nearest dollar amount as appropriate.
3June Cordes (docket No. 20254-94) and June J. Cordes
(docket Nos. 3305-96 and 4182-96) refer to the same person.
Hereinafter, June Cordes and June J. Cordes shall be referred to
as Mrs. Cordes or petitioner, as appropriate.
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