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J.O. Haney, Jr. and Patricia A. Haney (docket No. 22246-03):
Additions to Tax/Penalties, I.R.C.
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1996 $32,957 –- $6,591.40
1997 31,879 –- 6,375.80
1998 8,935 –- 1,787.00
1999 155,121 –- 31,024.20
2000 44,365 $11,048.85 8,873.00
2001 41,115 10,278.75 8,223.00
Blanco Springs Trust, Patricia A. Haney and Patricia J. Haney,
Trustees (docket No. 22294-03):
Additions to Tax/Penalties, I.R.C.
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1997 $10,722 –- $2,144.00
1998 5,429 –- 1,086.00
1999 10,917 –- 2,183.00
2000 2,823 –- 565.00
2001 9,559 $2,389.75 1,912.00
The issue for decision is whether certain trust arrangements will
be respected for tax purposes. Unless otherwise indicated, all
section references are to the Internal Revenue Code in effect for
the years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioners resided in or had their principal place of
business in Texas at the time that their respective petitions
were filed. Petitioners J.O. Haney, Jr. (J.O.), and Patricia A.
Haney (Patricia), collectively referred to as the Haneys, were
the parents of J.O. Haney, III (Joey), Patricia J. Haney, and
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