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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined the following Federal
income tax deficiencies and penalties with respect to
petitioners’ Federal income taxes:
Accuracy-Related Penalty
Year Deficiency Sec. 6662
1999 $4,750 $950.00
2000 6,710 1,342.00
2001 10,090 2,018.00
2002 2,577 515.40
The issues for decision are:
(1) Whether the income from the Lucky Kirt Irrevocable Trust
(Lucky Kirt Trust) should be attributed to petitioners;
(2) whether petitioners are liable for self-employment taxes
under section 14011 for the taxable years 1999 through 2002;
(3) whether petitioners are liable for tax on a capital gain
in taxable year 2001;
(4) whether petitioners are liable for accuracy-related
penalties under section 6662 for the taxable years 1999 through
2002; and
(5) 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 of 1986, as amended and in effect for
the years 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