HANI G. ATAYA,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
INAAM ATAYA,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
United States Tax Court
Filed June 4, 2025
Stephan M. Brown, for petitioners.
Sharyn M. Ortega, Nchekube U. Onyima, Kara L. Davidson Duyck, and Catherine J. Caballero, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WAY, Judge: Respondent issued a separate Notice of Deficiency to each petitioner in these consolidated cases determining deficiencies in petitioners’ 2015 and 2016 federal income tax and imposing section 66621 accuracy-related penalties. The Notices of Deficiency determined [*2] that petitioners received qualified dividends and other income that went unreported on their Forms 1040, U.S. Individual Income Tax Return. With respect to these income tax returns, the Notices of Deficiency also disallowed gross receipts and deductions…
