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OPINION
NIMS, Judge: Respondent determined the following
deficiencies and penalties with respect to petitioners’ Federal
income taxes:
Penalties
Petitioner Year Deficiency Sec. 6662(a) Sec. 6663
Thomas E. Johnston and *1989 $1,546,160 $309,232 $1,159,620
* * Shirley L. Johnston,
Deceased
Docket No. 26005-96
Thomas E. Johnston 1991 289,396 -- 217,047
Docket No. 2266-97
1992 341,908 -- 256,431
Eric T. Johnston 1989 165,067 33,013 --
Docket No. 12736-97
By answer respondent also asserted increased deficiencies and
penalties in docket Nos. 26005-96 and 2266-97.
These consolidated cases are presently before the Court on
two motions filed by respondent. Respondent filed a motion for
partial summary judgment with respect to docket Nos. 26005-96 and
2266-97 and a motion in limine with respect to docket Nos. 26005-
96, 2266-97, and 12736-97. A hearing was subsequently held, and
these motions were taken under advisement. Pursuant to orders of
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Last modified: May 25, 2011