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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.
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