T.C. Memo. 2001-196 UNITED STATES TAX COURT CHRISTOPHER K. AND BRENDA M. COX, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9989-99, 9990-99, Filed July 27, 2001. 9991-99. Gregory W. Bond, for petitioners. Ann L. Darnold, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: In separate notices of deficiency, respondent determined the following income tax deficiencies, 1 Cases of the following petitioners are consolidated herewith: Gregory A....
T.C. Memo. 2001-195 UNITED STATES TAX COURT MARK SUNIK AND TAMARA SUNIK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9941-99. Filed July 27, 2001. Jay J. Freireich, Harvey R. Poe, and Michael J. Sullivan, for petitioners. Keith V. Doce and Diane R. Mirabito, for respondent. MEMORANDUM OPINION WELLS, Chief Judge: Respondent determined a deficiency in petitioners' 1995 Federal income tax in the amount of $70,783 and a section 6662 accuracy-related penalty of $14,157....
T.C. Memo. 2001-231 UNITED STATES TAX COURT JERRY S. PAYNE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 980-95, 26812-95. Filed August 27, 2001. Jerry S. Payne, pro se. Richard T. Cummings, for respondent. SUPPLEMENTAL MEMORANDUM OPINION SWIFT, Judge: This matter is before us on petitioner’s motion under Rule 231 for an award of $42,376 in litigation costs under section 7430. * This opinion supplements our prior Memorandum Opinion, Payne v. Commissioner, T.C. Memo....
T.C. Summary Opinion 2001-152 UNITED STATES TAX COURT WILLIE CLAYBORN, JR. & JACQULYN A. CLAYBORN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 978-00S. Filed September 25, 2001. Willie Clayborn, Jr. and Jacqulyn A. Clayborn, pro sese. H. Clifton Bonney, Jr., for respondent. DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed. The decision to be entered is...
T.C. Memo. 2001-149 UNITED STATES TAX COURT ALACARE HOME HEALTH SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9566-99. Filed June 22, 2001. Robert C. Walthall, for petitioner. Marshall R. Jones, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined deficiencies in petitioner’s Federal income tax of $136,895 for 1995 and $58,726 for 1996 and accuracy-related penalties under section 6662(a) of $27,379 for 1995 and $11,...
T.C. Memo. 2001-162 UNITED STATES TAX COURT NICHOLAS P. RUGGIERO AND ANNETTE M. RUGGIERO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9561-00. Filed July 3, 2001. Nicholas P. Ruggiero and Annette M. Ruggiero, pro sese. Timothy S. Sinnott, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DEAN, Special Trial Judge: Respondent determined additions to petitioners' Federal income tax for 1983 under section 6653(a)(1)1 in the amount of $167.25 and under section 6653(...
T.C. Summary Opinion 2001-100 UNITED STATES TAX COURT SCOTT THOMAS AND JENNIFER GUNDRY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9543-00S. Filed July 2, 2001. Scott Thomas and Jennifer Gundry, pro se. Daniel J. Parent, for respondent. COUVILLION, Special Trial Judge: This case was heard pursuant to section 7463 in effect when the petition was filed.1 The decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority....
T.C. Memo. 2001-16 UNITED STATES TAX COURT MICHAEL G. HARVEY AND PENNY B. HARVEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9527-99. Filed January 25, 2001. Joel N. Crouch and Sarah Q. Qureshi, for petitioners. Rodney J. Bartlett, for respondent. MEMORANDUM OPINION DINAN, Special Trial Judge: Respondent determined that petitioner was liable for the following additions to tax for taxable year 1982: $452.25 under section 6653(a)(1), 50 percent of the interest due on a...
T.C. Memo. 2001-116 UNITED STATES TAX COURT BURIEN NISSAN, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9519-98, 12341-98, Filed May 14, 2001. 11536-99, 16916-99. J. Patrick Quinn, for petitioners. Roy Wulf, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined deficiencies and accuracy-related penalties for Burien Nissan, Inc. (Burien 1 Cases of the following petitioners are consolidated herewith: Burien Nissan, Inc....
T.C. Summary Opinion 2001-104 UNITED STATES TAX COURT JOHN MOSIER AND SARAH SPAIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9492-99S. Filed July 13, 2001. John Mosier, pro se. Scott T. Welch, for respondent. DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed. The decision to be entered is not reviewable by any other court, and this opinion should not be...
T.C. Memo. 2001-286 UNITED STATES TAX COURT CARROLL R. FURNISH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9490-99. Filed October 29, 2001. Carroll R. Furnish, pro se. Leonard T. Provenzale, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Respondent determined the following deficiencies in, addition to, and penalties on petitioner’s Federal income taxes: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662 1993 $67,215 $16,803.75 $...
T.C. Memo. 2001-80 UNITED STATES TAX COURT ROBERT COCO AND LAUREEN COCO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9460-00. Filed April 2, 2001. Ronald J. Cohen, for petitioners. Robin L. Peacock, for respondent. MEMORANDUM OPINION GERBER, Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court 1 Unless otherwise indicated, all section references are to the...
T.C. Memo. 2001-69 UNITED STATES TAX COURT DAVID R. BRADEN AND SHARON F. BRADEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9459-98. Filed March 22, 2001. Sharon F. Braden, pro se. Thomas E. Crowe, for petitioner David R. Braden. Fred E. Green, Jr., for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: Respondent determined a deficiency in petitioners’ Federal income tax of $16,525 and an accuracy- - 2 - related penalty under section 6662(a)1 of $2,...
T.C. Memo. 2001-214 UNITED STATES TAX COURT JUAN VEGA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9217-00. Filed August 10, 2001. Juan Vega, pro se. Kevin W. Coy, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: Respondent determined deficiencies in petitioner’s Federal income taxes for the taxable years 1996 and 1997 in the amounts of $2,578 and $2,014, respectively. - 2 - The issues for decision are as follows: (1) Whether...
T.C. Summary Opinion 2001-74 UNITED STATES TAX COURT RICHARD WILLIAM CORDUAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 920-00S. Filed May 31, 2001. Richard William Corduan, pro se. Mark J. Miller and Mark D. Petersen, for respondent. DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed. The decision to be entered is not reviewable by any other court, and...
T.C. Memo. 2001-264 UNITED STATES TAX COURT LEROY AND SHIRLEY COMBS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9198-00. Filed October 3, 2001. Leroy and Shirley Combs, pro sese. Dale A. Zusi, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: By notice dated May 24, 2000, respondent determined a $298,992 deficiency, a $74,598 section 6651(a) addition to tax, and a $59,798 section 6662(a) penalty relating to petitioners’ 1994 Federal income tax....
