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.
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