- 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
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