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Liability of Donald R. Cooley
Year Deficiency Sec. 6663(a) Penalties
1989 $2,982.63 $24,584.96
1990 2,617.74 28,705.73
1991 171.92 14,035.44
1992 -0- 21,045.16
1993 3,007.91 18,888.44
Liability of Cathy A. Cooley
Year Deficiency Sec. 6663(a) Penalties
1989 $2,982.63 -0-
1990 2,617.74 -0-
1991 171.92 -0-
1992 -0- -0-
1993 3,007.91 -0-
After concessions, the remaining issue to be decided in
docket No. 7464-00 is whether petitioner Donald R. Cooley
(hereinafter referred to individually as petitioner) is liable
for section 6663(a) penalties for fraud with respect to his 1989,
1990, 1991, 1992, and 1993 taxable years. Respondent did not
determine section 6663(a) penalties against petitioner Cathy A.
Cooley. In the case at docket No. 9452-00L, we must decide
whether respondent’s determination to proceed with the collection
of Federal income taxes assessed against petitioners for their
1989, 1990, 1991, 1992, 1993, and 1996 taxable years was
appropriate. All section references are to the Internal Revenue
Code, as amended, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
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Last modified: May 25, 2011