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MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: In these consolidated cases, respondent
determined the following deficiencies in, additions to, and
penalties on petitioners’ Federal income taxes:
Additions to Tax Penalty
Petitioners Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
Steve and 1994 $101,230 $25,457 $20,246
Khristine 1995 51,512 5,752 10,302
Norton 1996 71,217 -0- 14,243
Denali Co. 1994 119,980 29,995 23,996
Trust 1995 65,127 16,282 13,025
1996 77,351 -0- 15,470
South Denali
Lands Trust 1994 414 104 83
Unless otherwise stated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether income reported by
the South Denali Lands Trust and Denali Company Trust is
includable in the gross income of Mr. and Mrs. Norton; (2)
whether Mr. and Mrs. Norton are liable for additions to tax for
failure to file a tax return pursuant to section 6651(a)(1); (3)
whether Mr. and Mrs. Norton are liable for accuracy-related
penalties pursuant to section 6662(a); and (4) whether Mr. and
Mrs. Norton are liable for penalties imposed under section 6673.
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Last modified: May 25, 2011