2 MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: These cases were consolidated for trial, briefing, and opinion. In docket No. 7628-00, Victor and Judith A. Grigoraci (separately Mr. Grigoraci and Mrs. Grigoraci, respectively, and collectively the Grigoracis) sought redetermination under section 6213 of a deficiency for tax on self-employment income and a negligence accuracy-related penalty under section 6662(a).2 Respondent determined a deficiency of $12,670 and an accuracy-related penalty of $2,534 for 1996. In docket numbers 7890-00 and 9573-00, petitions were brought under section 6226 by the Tax Matters Partners of two partnerships: Trainer, Wright & Associates (TWA) and Grigoraci, Trainer, Wright & Paterno (GTWP).3 The petitioners in these cases sought readjustment of certain adjustments made by respondent to the partnerships’ 1996 tax returns. Both partnerships reported on Schedules K-1, Partner’s Share of Income, Credits, Deductions, Etc., that the partners in each partnership were corporations. Respondent determined that the partners of record were not the true and actual partners, but 2 Unless otherwise indicated, section references are to the Internal Revenue Code applicable to the subject years. Rule references are to the Tax Court Rules of Practice and Procedure. 3 Paterno is not a partner to GTWP. The partnership adopted the use of the Paterno name after purchasing a firm by the name of Howell and Paterno.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011