-2- MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Petitioners petitioned the Court to redetermine certain determinations made by respondent as to their Federal income tax liabilities. The Court consolidated the cases for purposes of trial, briefing, and opinion. Inasmuch as petitioner Sharon JoAnn Hickey is involved in these cases because she filed joint 1992 and 1993 Federal income tax returns with petitioner Patrick Carlin Hickey, we hereinafter use the singular “petitioner” to refer solely to Patrick Carlin Hickey. We refer to Sharon JoAnn Hickey as “Hickey”. Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure. In docket Nos. 9582-04 and 9592-04, petitioner petitioned the Court on June 8, 2004, to redetermine respondent’s determination of the following deficiencies, additions to tax, and penalties: Additions to tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6663 1989 $23,621 $5,201 $507 $17,716 1990 2,982 671 0 2,237 1991 23,964 5,392 48 17,495 1992 10,728 0 0 8,046 1993 2,674 165 318 2,006 Respondent reflected this determination in two notices of deficiency issued to petitioner on March 25, 2004. Respondent also determined in the notices of deficiency that petitioner isPage: 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