T.C. Memo. 1998-387 UNITED STATES TAX COURT KENNETH & LINDA J. LOGIE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9915-97. Filed October 29, 1998. Linda J. Logie, pro se. Rebecca T. Hill, and Marion T. Robus, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: Respondent determined a deficiency of $14,322 in petitioners' 1994 Federal income tax and a $2,864 accuracy-related penalty under section 6662(a). Unless otherwise indicated, all section...
T.C. Memo. 1998-227 UNITED STATES TAX COURT JERRY S. PAYNE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 980-95, 26812-95. Filed June 29, 1998. Jerry S. Payne, pro se. Richard C. Cummings, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: Respondent determined deficiencies in and additions to tax with regard to petitioner as follows: - 2 - Docket No. 980-95 Additions to Tax Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661 1987 $172,...
T.C. Memo. 1998-373 UNITED STATES TAX COURT ANNE R. DUGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9808-97. Filed October 15, 1998. Anne R. Dugan, pro se. Kimberley J. Peterson, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: Respondent determined a deficiency in petitioner's Federal income tax for the year 1994 in the amount of $11,402 and an addition to tax in the amount of $545 under section 6651(a)(1). - 2 - Unless otherwise indicated,...
T.C. Memo. 1998-365 UNITED STATES TAX COURT ESTATE OF ANN H. BROOKSHIRE, DECEASED, HARVEY B. KING, INDEPENDENT EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9804-96. Filed October 8, 1998. William R. Cousins III, Robert Don Collier, and Robert M. Bolton, for petitioner. Donna Mayfield Palmer, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: Respondent determined a deficiency of $3,509,857 in the Federal estate tax of the Estate of decedent...
T.C. Memo. 1998-83 UNITED STATES TAX COURT ROBERT G. RUCKMAN AND JULIE RUCKMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 976-95. Filed February 25, 1998. C. Page Hamrick III, for petitioners. William Henck, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: Respondent determined deficiencies in petitioners' Federal income taxes and an accuracy-related penalty as follows: Accuracy-Related Penalty Year Deficiency Sec. 6662(b)(1) 1989 $6,006 - 1990 6,...
T.C. Memo. 1998-430 UNITED STATES TAX COURT C.H. ROBINSON, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent C.H. ROBINSON, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9730-96, 26811-96. Filed December 8, 1998. William J. Hippee, Jr. and David B. Strong, for petitioners in docket Nos. 9730-96 and 26811-96. Edward J. Plumier, for petitioner in docket No. 9730-96. Jack Forsberg, for respondent. - 2 - MEMORANDUM FINDINGS OF FACT...
T.C. Memo. 1998-171 UNITED STATES TAX COURT LESTER JOHNSON AND SHERELLE D. BROOKS-JOHNSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9704-97. Filed May 11, 1998. Lester Johnson and Sherelle D. Brooks-Johnson, pro se. Scott Hargis, for respondent. MEMORANDUM OPINION DAWSON, Judge: This case was assigned to Special Trial Judge Larry L. Nameroff pursuant to section 7443A(b) and Rules - 2 - 180, 181, 183.1 The Court agrees with and adopts the opinion of the Special...
T.C. Memo. 1998-31 UNITED STATES TAX COURT RONALD D. CIARAVELLA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ICARUS, INCORPORATED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9650-96, 9651-96. Filed January 26, 1998. Russell S. Koss, for petitioners. Willie Fortenberry, Jr., for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION BEGHE, Judge: In these consolidated cases, respondent determined the following deficiencies and penalty with respect to...
T.C. Memo. 1998-187 UNITED STATES TAX COURT ANTHONY AND GLORIA DONNORA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9470-97. Filed May 21, 1998. R determined deficiencies and fraud additions to tax against H and W for 1988, 1989, and 1990. R’s answer asserts in par. 7 affirmative allegations of fraud against both H and W. R’s answer also asserts in par. 8 information regarding H’s conviction under sec. 7201, I.R.C. 1986, for 1988, 1989, and 1990, and contends that H...
T.C. Memo. 1998-188 UNITED STATES TAX COURT FORKSTON FIREWORKS MFG. CO., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9469-97. Filed May 21, 1998. H and W were owners and employees of P. H was convicted under sec. 7206(2), I.R.C. 1986, for aiding or assisting the filing of false tax returns as to P’s 1988, 1989, and 1990 income tax return. R filed a motion for summary judgment based on (1) H’s and W’s deemed admissions in another docket and (2) collateral estoppel...
T.C. Memo. 1998-51 UNITED STATES TAX COURT DANIEL E. GODFREY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9453-97. Filed February 9, 1998. Daniel E. Godfrey, pro se. Louise R. Forbes, for respondent. MEMORANDUM OPINION POWELL, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $751. Petitioner resided in Winthrop, Massachusetts,...
T.C. Memo. 1998-202 UNITED STATES TAX COURT JOE T. KIEFFER AND LINDA R. KIEFFER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9404-96. Filed June 2, 1998. Joe T. Kieffer and Linda R. Kieffer, pro sese. Gregory M. Hahn and Christal W. Hillstead, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal...
T.C. Memo. 1998-232 UNITED STATES TAX COURT LAIDLAW TRANSPORTATION, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent LAIDLAW INDUSTRIES, INC. & SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9361-94, 9362-94. Filed June 30, 1998. Robert H. Aland, Gregg D. Lemein, Mark A. Oates, Jeffrey M. O'Donnell, John D. McDonald, and Taylor S. Reid, for petitioners. Thomas R. Lamons, C. Glenn McLoughlin, and Brigham J.L. Sanders, for...
T.C. Memo. 1998-190 UNITED STATES TAX COURT THOMAS W. BOOZER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9328-97. Filed May 26, 1998. Thomas W. Boozer, pro se. Audrey Morris, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Chief Judge: Respondent determined deficiencies in Federal individual income tax and additions to tax under sections 6651(a)(1) (failure to file) and 6654 (underpayment of estimated income tax) against petitioner as follows: - 2 -...
T.C. Memo. 1998-137 UNITED STATES TAX COURT DANIEL L. FA’ASAMALA AND YVETTE S. FA’ASAMALA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9220-97. Filed April 9, 1998. Daniel L. Fa’Asamala and Yvette S. Fa’Asamala, pro sese. Fred E. Green, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined that, for the taxable year 1995, petitioners had a $10,603 income tax deficiency and a $2,121 accuracy-related penalty under section 6662(a).1...
T.C. Memo. 1998-371 UNITED STATES TAX COURT PAUL ARTHUR ZIPP, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9216-96. Filed October 13, 1998. Paul Arthur Zipp, pro se. Shirley M. Francis, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined deficiencies in petitioner's Federal income tax and fraud penalties for taxable years 1990, 1991, and 1992 as follows: Penalty Year Deficiency Sec. 6663 1990 $124,387 $93,290 - 2 - 1991 256,233...
