United States Tax Court, 2012

Leon v. Comm'r

Leon v. Comm'r
United States Tax Court · Decided April 12, 2012 · \Joseph Robert Goeke\""
2012 U.S. Tax Ct. LEXIS 50 (United States Reports)
Leon v. Comm'r

Opinion

ROBERT A. LEON & DEBRA D. COLBURN, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Leon v. Comm'r
Docket No. 21774-09
United States Tax Court
2012 U.S. Tax Ct. LEXIS 50;
April 12, 2012, Decided
*50
For Petitioner: Robert A. Leon, Debra D. Colburn, Abkin Law, LLP, San Francisco, CA; Katz, Steven M., Sideman & Bancroft, LLP, San Francisco, CA.
For Respondent: Doukas, Nicholas D., Denver, CO; Mackinson, Thomas R., San Francisco, CA.
Joseph Robert Goeke, Judge.

Joseph Robert Goeke
DECISION

Pursuant to the agreement of the parties in this case, it is

ORDERED AND DECIDED: That there are deficiencies in income tax due from petitioners for the taxable years 2003, 2004, and 2005 in the amounts of $350,973.00, $5,231.00, and $1,879.00, respectively; and

That there is a penalty due from petitioners for the taxable year 2003, under the provisions of I.R.C. § 6662(a), in the amount of $28,077.84.

/s/ Joseph Robert Goeke

Joseph Robert Goeke

Judge

Entered: APR 12 2012

It is hereby stipulated that the Court may enter the foregoing decision in this case.

It is further stipulated that interest will be assessed as provided by law on the deficiencies and penalty due from petitioners.

It is further stipulated that, effective upon the entry of this decision by the Court, petitioners waive the restrictions contained in I.R.C. § 6213(a) prohibiting assessment and collection of the deficiencies and penalty (plus statutory *51 interest) until the decision of the Tax Court becomes final.

WILLIAM J. WILKINS

Chief Counsel

Internal Revenue Service

/s/ Wendy Abkin

WENDY ABKIN

Abkin Law, LLP

Counsel for Petitioners

Tax Court Bar No. AW0237

One Embarcadero Center

Suite 1020

San Francisco, CA 94111

Telephone: (415) 956-3280

Date: 4/5/2012

By: /s/ Thomas R. MacKinson

Acting THOMAS R. MACKINSON

Associate Area Counsel

(Small Business/Self-Employed)

Tax Court Bar No. MT0403

100 First Street

Suite 1800

San Francisco, CA 94105

Telephone: 415-547-3764

Date: 4-6-2012

Case-law data current through December 31, 2025. Source: CourtListener bulk data.