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NHUSS Trust:
Year Deficiency Penalty
1999 $358,038 $71,608
2000 329,456 65,891
In God and Trust, a.k.a. In God We Trust (In God We Trust):
Year Deficiency Penalty
1999 $58,072 $11,614
2000 66,074 13,215
RJ Pendergraft Trust, Joyce Pendergraft, Trustee:
Year Deficiency Penalty
1999 $ 95,958 $19,192
2000 438,772 87,754
Riley and Joyce Pendergraft:
Year Deficiency Penalty
1999 $416,081 $83,216
2000 445,987 89,197
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. All references to petitioners are to petitioners
Riley and Joyce Pendergraft, and all references to petitioner in
the singular are to Riley Pendergraft.
After concessions by all parties (particularly a concession
collapsing the income and expenses of the above three trusts for
each year into petitioners’ income and expenses) and settlements
entered into by all parties (particularly settlements relating to
various business and personal deductions), the only remaining
issues for decision are: (1) The amount of petitioners’ gain on
the sale of their residence; (2) the fair market value of a van
on the date the van was donated to charity; and (3) petitioners’
liability for the negligence penalty under section 6662(a) in the
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Last modified: May 25, 2011