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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined a Federal income tax
deficiency for Terry Major’s 2001 taxable year in the amount of
$5,613 and an addition to tax pursuant to section 6651(a)(1) in
the amount of $1,403.25 and for Louise Major’s 2001 taxable year
a Federal income tax deficiency in the amount of $1,016 and an
addition to tax pursuant to section 6651(a)(1) in the amount of
$254.1 The issues for decision are:
(1) Whether petitioner Terry Major (Terry) is liable for a
deficiency in the amount of $5,613 for the 2001 taxable year;
(2) whether petitioner Louise Major (Louise) is liable for a
deficiency in the amount of $1,016 for the 2001 taxable year;
(3) whether petitioners are liable for additions to tax
under section 6651(a)(1); and
(4) whether the Court should impose a penalty, sua sponte,
under section 6673.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the year in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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Last modified: May 25, 2011