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SETTIMO v. COMMISSIONER

Docket No. 5153-05.

92 T.C.M. 473 (2006)

T.C. Memo. 2006-261

Frank M. Settimo and Sallyn M. Settimo v. Commissioner.

United States Tax Court.

December 7, 2006.

Attorney(s) appearing for the Case

Joseph Falcone, for petitioners.

Laurie B. Schmidt and John W. Stevens, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court to redetermine respondent's determination of deficiencies of $18,243 and $19,917 in their 2001 and 2002 Federal income taxes, respectively, and section 6662 accuracy-related penalties of $3,648.60 and $3,983.40, respectively. Following the parties' concessions, we are left to decide whether two S corporations (collectively, S corporations) wholly owned by Frank Settimo...

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