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for petitioner.
John C. McDougal, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
CHABOT, Judge: This matter is before us on the parties’
dispute as to entry of decision pursuant to Rule 155,2 regarding
the additions to tax under section 66613 (substantial
understatement of income tax) for 1985 and section 6653(b)(1)(A)
(fraud) for 1986.
Our opinion in these cases, Grossman v. Commissioner, T.C.
Memo. 1996-452, primarily concerned whether petitioner, a tax
attorney, committed fraud by failing to report constructive
dividends after causing a group of closely held corporations to
pay for his family's vacation trips. In that opinion, we held
petitioner liable for fraud additions to tax for 1985 and 1986;
also we concluded that petitioner conceded the section 6661
addition to tax for 1985.
1(...continued)
memorandum of law.
2 Unless indicated otherwise, all Rule references are to
the Tax Court Rules of Practice and Procedure.
3 Unless indicated otherwise, all section references are
to sections of the Internal Revenue Code of 1954, or the Internal
Revenue Code of 1986, as in effect for the respective years in
issue.
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