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penalties for the tax years 1994, 1995, 1996, and 1997 as
follows:2
WFO Corp.
docket No. 6913-02
Accuracy-related
Penalties Addition to Tax
Year Deficiencies Sec. 6662(a) Sec. 6551(a)(1)
1995 $1,725 $345.00 $431.25
1996 95,228 19,045.60 0
Terence J. and Giselle M. Wolfe
docket No. 6914-02
Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1996 $22,762 $130.25
Terence J. Wolfe
docket No. 6915-02
Additions to Tax
Year Deficiencies Sec. 6651(a)(1) Sec. 6654
1994 $1,980 $99.00 $102.75
1995 11,875 593.75 643.88
Giselle M. Wolfe
docket No. 6916-02
Accuracy-related
Penalty
Year Deficiencies Sec. 6662(a)
1995 $728 0
1997 3,914 $148.40
Respondent has moved for entry of decisions with respect to
these cases based on a stipulation of settled issues signed by
the parties’ counsel and filed on March 13, 2003. The
2 Unless otherwise noted, all section references are to the
Internal Revenue Code as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
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