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petitioner is liable for additions to tax for failure to file
under section 6651(a)(1) of $100 for 1994 and $120 for 1997,2 and
for failure to pay estimated tax under section 6654 of $18.99 for
1997. For the addition to tax for failure to file under section
6651(a)(1) for 1996, respondent determined that Nancy S. Johnston
is liable for $100 and that William H. Johnston is liable for
$61.3
The issues for decision are:
1. Whether petitioners each have deficiencies in income
tax in the amounts respondent determined for 1994, 1996, and
1997. We hold that they do.
2. Whether petitioners are each liable for additions to tax
for failure to file under section 6651(a)(1) for 1994, 1996, and
1997, and for failure to pay estimated tax under section 6654 for
1997. We hold that they are.
3. Whether petitioners are liable for a penalty under
section 6673 for instituting proceedings primarily for delay and
1(...continued)
property law, each petitioner received one-half of the total
income received by petitioners in 1994, 1996, and 1997. Tex.
Fam. Code Ann. secs. 3.001-3.309 (Vernon 2002).
2 Respondent also determined that petitioners are liable
for additions to tax for failure to pay tax under sec. 6651(a)(2)
for 1996 and 1997. Respondent concedes that petitioners are not
liable for additions to tax under sec. 6651(a)(2) for 1996-97.
3 Respondent determined a larger addition to tax under sec.
6651(a)(1) for 1996 for Nancy S. Johnston because less tax was
withheld from her than from William H. Johnston.
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