John E. Hunter, II and Alma E. Hunter - Page 2

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          Trial Judge Peter J. Panuthos.  His recommended findings of fact            
          and conclusions of law were filed and served upon the parties on            
          October 5, 2006.  There were no objections filed as provided in             
          Rule 183(c).  Unless otherwise indicated, all section references            
          are to the Internal Revenue Code as amended and in effect for the           
          years in issue, and all Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
               Rule 183(d) provides that due regard shall be given to the             
          circumstance that the Special Trial Judge had the opportunity to            
          evaluate the credibility of witnesses, and the findings of fact             
          recommended by the Special Trial Judge shall be presumed to be              
          correct.  None of the issues in these cases, however, turns on              
          the credibility of witnesses.  We have given appropriate                    
          deference to the Chief Special Trial Judge’s recommended factual            
          findings.  After consideration of the evidence and the record in            
          these cases, we have made minor, clarifying, stylistic, and                 
          editorial changes to his recommended findings of fact and                   
          conclusions of law.  We conclude that the recommended findings of           
          fact and conclusions of law of Chief Special Trial Judge Peter J.           
          Panuthos, which are hereinafter set forth as modified, should be            
          adopted as the report of the Court.                                         
               These cases were consolidated by Order of this Court dated             
          February 13, 2006.  The case at docket No. 23649-04 arises from a           
          petition filed in response to a notice of deficiency issued on              

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