Extract
Debra L. Streck and Donald W. Streck, (1997)
T.C. Memo. 1997-407
UNITED STATES TAX COURT DEBRA L. STRECK AND DONALD W. STRECK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25246-95. Filed September 15, 1997.Debra L. Streck and Donald W. Streck, pro sese. Joseph P. Grant, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:Additions to Tax Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661 1983 $142,520 $71,260 50 percent of $35,630 the interest due on $142,520 1984 369,494 184,747 50 percent of 92,374 the interest due on $191,310 1985 543,404 271,702 50 percent of 135,086 the interest due on $412,774Additions to Tax Year Deficiency Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) 1986 $111,494 $5,575 50 percent of the interest due on $111,494Respondent's determination was based on the following items: Unreported gross income;1 disallowance of a net operating loss carryover;2 allowance of a deduction for two-earner married couples;3 an increase in capital gains;4 and disallowances of various deductions for business losses and expenses.5 Petitioners concede the adjustments made by respondent for unreported gross income, the allowance of the two-earner deduction, and the increase to capital...See the full content of this document
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