Maureen Monsour - Page 10

                                       - 10 -                                         
          his interest in the residence of petitioner and Mr. Monsour.                
               In 1991, Mr. Monsour transferred to petitioner one-half of             
          his interest in the Open Heart property.                                    
               In 1997, Mr. Monsour transferred to petitioner one-half of             
          his interest in 30 acres of land, which at all relevant times he            
          and one of his brothers (Howard Monsour) owned and which was                
          located behind Monsour Medical Center, a hospital that Mr.                  
          Monsour had owned and operated at all relevant times since 1964.            
               In 1997, Mr. Monsour transferred to petitioner one-half of             
          his interest in Laurel Valley Farms.                                        
               At a time not disclosed by the record, petitioner and Mr.              
          Monsour jointly filed Form 1040, U.S. Individual Income Tax                 
          Return (Form 1040), for each of their taxable years 1987 and                
          1988.                                                                       
               On March 19, 1993, respondent issued to petitioner and Mr.             
          Monsour a notice of deficiency (notice) with respect to their               
          taxable years 1987 and 1988 (notice for the taxable years 1987              
          and 1988).  In that notice, respondent determined the following             
          deficiencies in, and additions to, the tax of petitioner and Mr.            
          Monsour:                                                                    

                           Additions to Tax                                           
                             Sec.          Sec.          Sec.        Sec.             
          Year Deficiency  6653(a)(1)  6653(a)(1)(A) 6653(a)(1)(B)   6661             
          1987   $15,851      --          $1,066          1         $5,332            
          1988   21,416      $1,627         --           --         8,133             
               150% of the interest due on the deficiency.                            





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