James G. and Linda C. Jaroff, (2004)
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James G. and Linda C. Jaroff, (2004)
T.C. Memo. 2004-276
UNITED STATES TAX COURT JAMES G. AND LINDA C. JAROFF, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19193-99. Filed December 8, 2004.Steven D. Morford, for petitioners. Nhi T. Luu-Sanders, for respondent.MEMORANDUM OPINION WOLFE, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b)(5) in effect when these proceedings commenced, and Rules 180, 181, and 183. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.By notice of deficiency, respondent determined deficiencies in petitioners' Federal income tax, additions to tax under section 6651(a), and accuracy-related penalties under section 6662 as follows:Additions to Tax/Penalties Sec. Sec. Sec. Sec. Sec. Year Deficiency 6651(a) 6662(h) 6662(e) 6662(d) 6662(c) 1994 $15,535 $2,264 $6,214 $3,107 $3,107 $3,107 1995 8,837 507 3,415 1,707 1,707 1,707Petitioners have conceded that they are liable for deficiencies of $15,535 for 1994 and $8,837 for 1995. The remaining issues for decision are: (1) Whether petitioners are liable for additions to tax under section 6651(a) for filing the...See the full content of this document
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