- 2 -
section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Chief Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This case is before
the Court on respondent’s motions for entry of decision in
accordance with the parties’ stipulation of settled issues filed
on May 14, 2002. As explained in detail below, we shall grant
respondent’s motions.
Background
Respondent issued petitioners a statutory notice of
deficiency, dated January 27, 1999, determining the following
income tax deficiencies, additions to tax, and penalties:
Additions to Tax Penalty
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a) 6653(a)(1)(A) 6653(a)(1)(B) 6653(a) 6654 6662(a)
1986 $20,235 $5,059$1,012 50% of the ---$980 ---
interest due
on $20,235
1987 48,438 12,110 2,422 50% of the--- 2,618 ---
interest due
on $48,438
1988 36,091 9,023 --- --- $1,805 2,308 ---
1989 37,235 9,309 --- --- --- 2,515 $7,447
1990 38,968 8,992 --- --- --- 2,370 7,194
1991 55,343 13,836 --- --- --- 3,185 11,069
The adjustments to income in the notice of deficiency were
primarily due to respondent’s disallowance of various deductions
claimed on Schedule A and to the disallowance of total expenses
1 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 9 Next
Last modified: May 25, 2011