Ella Freidus - Page 1















                                 T.C. Memo. 1999-195                                   


                               UNITED STATES TAX COURT                                 


                             ELLA FREIDUS, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       


               Docket No. 24197-97.                    Filed June 16, 1999.            


                    On the facts, Held: R has established by clear and                 
               convincing evidence that at least part of F's underpayment              
               for the taxable years 1987 and 1988 is attributable to fraud            
               with the intent to evade tax and that F's failure to file               
               her 1989 and 1990 tax returns is attributable to fraud.  See            
               secs. 6651(f), 6653(b), I.R.C.                                          
                    Held, further, R's determination that F is liable for              
               the additions to tax under sec. 6653(b)(1)(A) and (B),                  
               I.R.C., for the 1987 taxable year, sec. 6653(b)(1)(A),                  
               I.R.C., for the 1988 taxable year and sec. 6651(f), I.R.C.,             
               for the 1989 and 1990 taxable years is sustained.                       


               Richard H. Champion, for petitioner.                                    
               Monica E. Koch and Richard Wright, for respondent.                      








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