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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.
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Last modified: May 25, 2011