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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.
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