Kenneth and Dorothy Hitchen - Page 2

                                        - 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