- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011