-2- 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.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007