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trial, the parties stipulated that there are no deficiencies in
Federal income tax or penalties due from petitioners G. Kierstead
Family Holdings Trust or G. Kierstead Family Trust. Respondent
determined Federal income tax deficiencies and penalties for
petitioners2 Glenn and Carol Kierstead as follows3:
Year at Issue Deficiency Sec. 6662(a)
2001 $40,410 $8,080
2002 38,165 7,633
2003 66,179 13,235
The parties filed a stipulation of settled issues necessary
for a determination of the amount of the liability for the years
in question, other than applicable penalties. Accordingly, the
only issue to be determined is whether petitioners Glenn and
Carol Kierstead are liable for accuracy-related penalties under
section 6662(a) for 2001, 2002, and 2003 (years at issue).4
FINDINGS OF FACT
2Unless otherwise indicated, reference to “petitioners”
shall mean petitioners Glenn E. and Carol L. Kierstead as
individuals.
3Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. All Rule references are
to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
4The parties stipulated that petitioners are liable for
accuracy-related penalties under sec. 6662(a) for 2001, 2002, and
2003 for the portion of their deficiencies allocable to their
failure to include interest income in the amounts of $8,633,
$8,465, and $8,174, respectively.
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Last modified: November 10, 2007