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Additions to tax and penalties
Year Deficiency Sec. 6653(a) Sec. 6651 Sec. 6662
1987 $1,197,033 $63,143 $269,331.98 --
1988 274,146 16,379 61,682.50 --
1989 10,253 –- 2,307.20 $2,050.60
1990 112,208 –- 25,247.25 22,441.60
1992 82,632 –- 18,592.68 26,526.40
1993 1,744 –- –- 354.80
1994 17,581 –- –- 3,516.20
1995 19,992 –- –- 3,998.40
1996 16,702 –- –- 3,340.40
1997 20,177 –- –- 4,035.40
This case is before the Court to decide the following
issues:
1. Whether respondent timely issued the notice of
deficiency to petitioner for tax years 1987-90 and 1992-95.
Resolution of that issue depends on whether petitioner filed his
1987-90 and 1992-95 Federal income tax returns when he hand
delivered those returns to respondent’s offices at 31 Hopkins
Plaza, Baltimore, Maryland, on February 21, 1997. We hold that
his delivery of the returns on that date did not constitute
filing and that the notice of deficiency was timely issued.
2. Whether petitioner is barred by res judicata from
carrying forward net operating losses from 1981-86 to the years
in issue. We hold that he is.
3. Whether to grant petitioner’s motion to dismiss this
case and to impose sanctions on respondent under Rule 104(c). We
will deny petitioner’s motion.
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