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Additions to Tax
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
1987 $21,182 $15,887 1 $5,296
1 50 percent of the interest payable pursuant to sec. 6601 with respect to the
portion of any underpayment that is due to fraud.
Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6653(b)(1) Sec. 6654
1988 $10,300 N/A $7,725 $659
1989 16,103 $12,077 N/A 1,089
Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
The issues to be decided in the instant case are:
(1) Whether petitioner is entitled to a deduction for home
mortgage interest for taxable year 1987 in an amount greater than
that allowed by respondent;
(2) whether petitioner failed to report income from a sole
proprietorship for each of taxable years 1987, 1988, and 1989 in
the amounts determined by respondent;
(3) whether petitioner is liable for self-employment tax
for each of taxable years 1987, 1988, and 1989;
(4) whether petitioner is liable for the additions to tax
for fraud pursuant to section 6653(b)(1)(A) and (B) for taxable
year 1987 and section 6653(b)(1) for taxable year 1988, and for
fraudulent failure to file pursuant to section 6651(f) for
taxable year 1989;
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Last modified: May 25, 2011