T.C. Memo. 1999-18 UNITED STATES TAX COURT LEEMA ENTERPRISES, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 39476-85, 41343-85, Filed January 28, 1999. 41987-85, 4797-86, 22921-86, 25313-86, 8648-93. Matthew D. Lerner, for petitioners in docket Nos. 39476-85, 41987-85, 4797-86, and 25313-86. Maria Rivera, pro se in docket Nos. 41343-85 and 22921-86. Matthew D. Lerner, Sidney J. Machtinger, and Lisa M. Zarlenga, for petitioner in docket No. 8648-93. 1...
T.C. Memo. 1999-16 UNITED STATES TAX COURT AJF TRANSPORTATION CONSULTANTS, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 12590-95, 24190-96, Filed January 28, 1999. 24482-96, 24483-96. J is a corporation engaged in furniture delivery services. F is J's sole shareholder and president. J's client issued checks to J for its delivery services and for fuel costs. F cashed the checks personally and diverted the funds for his own personal benefit. None of the...
T.C. Memo. 1999-418 UNITED STATES TAX COURT DAVID ANTHONY AVERY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9970-98. Filed December 23, 1999. David Anthony Avery, pro se. Jeanne Gramling, for respondent. MEMORANDUM OPINION POWELL, Special Trial Judge: Respondent determined a deficiency in petitioner’s 1994 Federal income tax and an accuracy-related penalty under section 6662(a)1 in the respective amounts of $4,940 and $988. 1 Section references are to the Internal...
T.C. Memo. 1999-395 UNITED STATES TAX COURT ESTATE OF FREDERICK R. HOFFMAN, DECEASED, MARILYN C. HOFFMAN, EXECUTOR, AND MARILYN C. HOFFMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9952-98. Filed December 6, 1999. Frank Agostino, Susan M. Flynn, and Andrew D. Engel, for petitioners. Craig Connell and Francis J. Strapp, Jr., for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: By notice dated April 3, 1998, respondent determined deficiencies of $63,...
T.C. Memo. 1999-349 UNITED STATES TAX COURT RONALD AND BARBARA KIMMICH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 994-90. Filed October 21, 1999. David A. Carris, for petitioners. Timothy S. Sinnott, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined deficiencies in, and additions to, petitioners' Federal income taxes, as follows: - 2 - Increased Additions to Tax Interest Year Deficiencies Sec. 6653(a)(1) Sec. 6653(a)(2)...
T.C. Memo. 1999-108 UNITED STATES TAX COURT PIZZA INDUSTRIES, INC. DOMINO'S PIZZA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9942-97. Filed April 2, 1999. Paul W. Rowe and Kevin M. Bagley, for petitioner. Gretchen A. Kindel, for respondent. MEMORANDUM OPINION ARMEN, Special Trial Judge: This matter is before the Court on petitioner's motion for an award of administrative and litigation costs under section 7430 and Rules 230 through 233.1 1 Unless otherwise indicated,...
T.C. Memo. 1999-154 UNITED STATES TAX COURT HELEN C. HOPKINSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9931-97. Filed May 5, 1999. Helen C. Hopkinson, pro se. David Delduco, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined deficiencies in and penalties on petitioner's Federal income taxes as follows: Penalty Year Deficiency Sec. 6662(a) 1993 $7,665 $1,533 1994 11,207 2,241 - 2 - Unless otherwise indicated all section...
T.C. Memo. 1999-20 UNITED STATES TAX COURT RICHARD T. STANLEY, SR. AND MIRIAM STANLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 987-97. Filed January 29, 1999. Held: P has failed to establish the existence, amount, or worthlessness in the years at issue of claimed nonbusiness and business bad debts. P has also failed to substantiate itemized deductions disallowed by R. P is liable for accuracy-related penalties for negligence under sec. 6662, I.R.C. Robert N....
T.C. Memo. 1999-175 UNITED STATES TAX COURT WIN H. EMERT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 9817-96. Filed May 24, 1999. David M. Kirsch, for petitioner. Steven Walker, for respondent. SUPPLEMENTAL MEMORANDUM OPINION VASQUEZ, Judge: The controversy before us arises out of * On August 6, 1998, the Court issued its opinion on the merits (T.C. Memo. 1998-289), which we incorporate herein. We sustained respondent's determination that (1) the method of accounting...
T.C. Memo. 1999-21 UNITED STATES TAX COURT JAMES F. McGUIRL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9715-96. Filed January 29, 1999. James F. McGuirl, pro se. William J. Gregg and William P. Simonsen, for respondent. MEMORANDUM OPINION DAWSON, Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court 1 Unless otherwise indicated, section references are to...
T.C. Memo. 1999-138 UNITED STATES TAX COURT PAUL F. DICKIE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent PAUL F. DICKIE AND SHERRY L. DICKIE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9614-98, 9615-98. Filed April 26, 1999. Leslie A. Anderson, for petitioners. Gail K. Gibson, for respondent. MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the...
T.C. Memo. 1999-347 UNITED STATES TAX COURT LEE F. PARKER AND DIANE K. PARKER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9590-98. Filed October 20, 1999. For purposes of deferring gain on the sale of their former residence under sec. 1034, I.R.C., Ps sought to include expenditures made in the construction of an unfinished dwelling structure. The structure was located on the same lot as the new residence purchased by Ps, and Ps intended eventually to use both...
T.C. Memo. 1999-209 UNITED STATES TAX COURT RIVER CITY RANCHES #4, J.V., WALTER J. Hoyt III, TAX MATTERS PARTNER, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9551-94, 9553-94, Filed June 22, 1999. 13596-94, 13598-94, 384-95, 387-95, 14721-95, 14723-95, 21630-95. Walter J. Hoyt III (tax matters partner), pro se. 1 The following cases are consolidated herewith: River City Ranches #6, J.V., Walter J. Hoyt III, Tax Matters Partner, docket No. 9553-94; River City...
T.C. Memo. 1999-248 UNITED STATES TAX COURT FRANKLIN D. AND SANDRA M. TERRELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9473-97. Filed July 28, 1999. Held: R's determination that Ps are liable for the addition to tax under sec. 6651(a)(1), I.R.C., for failure to timely file their Federal income tax returns for their 1991, 1992, and 1993 taxable years is sustained. Held, further, R's determination that Ps are liable for the accuracy-related penalty under sec. 6662(a)...
T.C. Memo. 1999-101 UNITED STATES TAX COURT JERRY AND PATRICIA A. DIXON, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 9382-83, 17646-83, Filed March 30, 1999. 4201-84, 7323-84, 15907-84, 20119-84, 40159-84, 22783-85, 30010-85, 30979-85, 29643-86, 35608-86, 19464-92, 621-94, 7205-94, 9532-94, 17992-95, 17993-95. 1 Cases of the following petitioners are consolidated herewith: Ronald L. Alverson and Mattie L. Alverson, docket No. 17646-83; Hoyt W. and Barbara D....
T.C. Memo. 1999-229 UNITED STATES TAX COURT JERRY LEE HARVEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9376-88, 7127-92, Filed July 12, 1999. 13113-96. James D. McMaster, for petitioner. W. Robert Abramitis, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined deficiencies in, additions to, and a penalty on petitioner's Federal income taxes as follows: - 2 - Docket No. 9376-88 Additions to Tax Year Deficiency Sec. 6653(b) Sec....
T.C. Memo. 1999-186 UNITED STATES TAX COURT HUMES HOUSTON HART, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9355-98. Filed June 8, 1999. Humes Houston Hart, pro se. Judith Cohen, for respondent. MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. All Rule references...
T.C. Memo. 1999-89 UNITED STATES TAX COURT LINDA RUTH PALMER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9338-97. Filed March 23, 1999. Clinton M. Fried and Kirk S. Chaberski, for respondent. MEMORANDUM OPINION WELLS, Judge: This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121. Unless otherwise indicated all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the...
T.C. Memo. 1999-416 UNITED STATES TAX COURT ROBERT C. AND DIANA J. WATTS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9289-98. Filed December 23, 1999. Cheryl Frank and Gerald W. Kelly, Jr., for petitioners. Elizabeth A. Owen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and an addition to tax and a penalty as follows: Addition to tax and penalty Year Deficiency Sec. 6651(a)...
T.C. Memo. 1999-117 UNITED STATES TAX COURT ALLEN BURDITT II AND SARAH MAUNEE S. BURDITT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 916-96. Filed April 6, 1999. Kenneth A. Love, for petitioners. Carol B. McClure and Andrew M. Tiktin, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: Respondent determined the following deficiencies, addition to tax, and accuracy-related penalties for the taxable years 1991, 1992, and 1993: Addition to Tax Penalty...
