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.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011