- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: By notices dated June 7 and 8, 1999, respondent determined deficiencies, additions to tax, and penalties relating to petitioners’ Federal income tax as follows: Joseph D. and Mi Jung Park, docket No. 13778-99 Additions to Tax Year Deficiency Sec. 6651(a)(1)2 Sec. 6662(a) 1992 $105,638 $26,407 $21,128 1993 157,576 39,394 31,515 John N. Park, docket No. 13784-99 Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1990 $321,294 $79,401 $64,259 1991 128,427 31,142 25,685 1992 118,697 5,920 23,739 1993 654,754 163,360 130,951 David S. and Deborah Park, docket No. 13789-99 Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $100,630 $25,097 $20,126 1993 101,233 -- 20,247 1994 237,580 -- 47,516 The issues for decision are whether petitioners: (1) Underreported income during the years in issue, and (2) are liable for section 6651 additions to tax and section 6662(a) accuracy-related penalties. 2 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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