Estate of Robert J. Capehart, Deceased, Ingrid Capehart, Personal Reprensentative, and Ingrid Capehart - Page 3

                                        - 3 -                                         
                                       OPINION                                        

               JACOBS, Judge: Respondent determined the following                     
          deficiency in petitioners’ Federal income tax and accuracy-                 
          related penalties for 1994:1                                                
                                   Accuracy-Related Penalty                           
                              Sec.      Sec.      Sec.      Sec.                      
               Deficiency     6662(h)   6662(e)   6662(d)   6662(c)                   
               $17,059        $6,823    $3,411    $3,411    $3,411                    
               In the second amendment to petition, Ingrid Capehart                   
          (petitioner) elected and requested relief from tax liability                
          under section 6015(b), (c), and (f).                                        
               The parties have filed a stipulation of settled issues and a           
          stipulation of facts.  In the stipulation of settled issues the             
          parties have settled the substantive issues for determining the             
          deficiency and the penalties.  The parties agree that petitioners           
          have a Federal income tax deficiency of $8,225 and are liable for           
          an accuracy-related penalty under section 6662(a) in the amount             
          of $507 for 1994.  In addition, petitioner no longer seeks relief           
          under section 6015(b) and (f), and respondent agrees that                   
          petitioner is entitled to relief under section 6015(c).                     





               1Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect at all relevant times.                      






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