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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 is
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