-2- MEMORANDUM OPINION2 LARO, Judge: These cases were consolidated for purposes of trial, briefing, and opinion. In a notice of deficiency dated April 28, 2005, respondent determined the following deficiencies and additions to tax with respect to John M. Smoll’s (petitioner’s) 1999, 2002, and 2003 Federal income taxes: Additions to Tax Year Tax Sec. 6651(f) Sec. 6654 1999 $30,620 $22,966 $1,482 2002 118,533 88,900 3,961 2003 85,312 63,984 2,233 In a second notice of deficiency dated April 28, 2005, respondent determined the following deficiencies, additions to tax, and penalties with respect to petitioners’ 2000 and 2001 Federal income taxes: Addition to Tax Penalty Year Tax Sec. 6651(a)(1) Sec. 6663 2000 $21,930 $5,482 $16,447 2001 24,890 6,222 18,667 Respondent filed a motion to dismiss this case for lack of prosecution, and we are left to decide the propriety of 2 We found the facts of this case from matter that was deemed stipulated under Rule 91(f) and from testimony that was elicited at trial. For convenience, we have incorporated our findings of fact with our opinion. 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. Dollar amounts are rounded. When their petitions were filed, petitioners resided in Sturgis, Michigan.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011