- 2 - and adopts the opinion of the Special Trial Judge, as set forth below. OPINION OF THE SPECIAL TRIAL JUDGE GOLDBERG, Special Trial Judge: In these consolidated cases,2 respondent determined the following deficiencies in petitioners’ Federal income taxes, additions to tax, and accuracy-related penalties, for the respective taxable years: Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6651 6653(a) 6659 6661 1984 $7,444 n/a 1$372$2,233 $1,861 1985 6,842 n/a 13422,053 1,711 1987 6,532 2$474 1415 1,960 1,633 1988 7,620 n/a 381 2,215 1,905 Accuracy-Related Penalties Sec. Sec. Sec. Sec. Year Deficiency 6662(c)3 6662(d)3 6662(e)3 6662(h)3 1989 $9,788 $1,958 $1,958 $1,958 $3,915 1In addition, respondent determined that petitioners are liable for the sec. 6653 addition to tax equal to 50 percent of the interest due on the deficiency in 1984, 1985, and 1987. 2Respondent conceded this addition to tax at trial. 3Sec. 6662(c), (d), (e), and (h) refers to the sec. 6662(a) accuracy-related penalty for negligence or disregard of rules or regulations, substantial understatement of income tax, substantial valuation overstatement, and gross valuation misstatement, respectively. Respondent further determined that the entire amount of the deficiencies in 1984, 1985, 1987, and 1988 is subject to the 1(...continued) all Rule references are to the Tax Court Rules of Practice and Procedure. 2In docket No. 1827-95, petitioners’ taxable years 1984, 1985, 1988, and 1989 are in dispute. In docket No. 9864-95, petitioners’ taxable year 1987 is in dispute.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