Kevin L. and Victoria L. Hargrove, et al. - Page 2

                                         -2-                                          
          (the years at issue)2 and accuracy-related penalties under                  
          section 6662(a).3                                                           
               Respondent determined that petitioners Kevin L. and Victoria           
          L. Hargrove were liable for a $11,814 deficiency and a $2,362.80            
          accuracy-related penalty for 2000.  For 2001, respondent                    
          determined that petitioners Mr. and Mrs. Hargrove were liable for           
          a $8,497 deficiency and a $1,699.40 accuracy-related penalty.               
               Respondent determined that petitioners William C. and                  
          Deborah L. Kirkpatrick were liable for a $1,943 deficiency in               
          2000 and a $1,843 deficiency in 2001.                                       
               Respondent determined that petitioners David J. and Ann M.             
          Nakagawa were liable for a $1,862 deficiency and a $372 accuracy-           
          related penalty for 1999.  For 2000, respondent determined that             
          petitioners Mr. and Mrs. Nakagawa were liable for a $1,848                  
          deficiency and a $370 accuracy-related penalty.  For 2001,                  
          respondent determined that petitioners Mr. and Mrs. Nakagawa were           
          liable for a $1,841 deficiency and a $368 accuracy-related                  
          penalty.                                                                    
               Respondent determined that petitioners Robert C. and Yvonne            
          R. Anthony were liable for a $2,332 deficiency for 2000, a $2,396           
          deficiency for 2001, and a $2,158 deficiency for 2002.                      

               2Not all petitioners had a deficiency for each year at                 
          issue.  The term “relevant years” will be used to refer to the              
          years for which respondent determined deficiencies for those                
          particular petitioners.                                                     
               3All section references are to the Internal Revenue Code in            
          effect for the years at issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  




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