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Addition to tax and penalties
Year Deficiency Sec. 6651(f) Sec. 6654 Sec. 6663
1993 $52,022 $38,266.50 $2,137.78
1994 89,820 67,365.00 4,660.89
1995 146,427 $109,820.25
Respondent concedes that petitioner is not liable for the
addition to tax for fraudulent failure to file for 1993 and 1994
under section 6651(f). Respondent also determined that, if
petitioner is not liable for fraudulent failure to file under
section 6651(f) for 1993 and 1994, then he is liable for fraud
under section 6663(a) for those years. Alternatively, respondent
determined that petitioner is liable for an addition to tax for
failure to timely file under section 6651(a) and an accuracy-
related penalty under section 6662(a) for 1993-95.
After concessions, the issues for decision are:
1. Whether petitioner had unreported gross receipts in 1993
of $252,006, as petitioner contends, or $345,172, as respondent
contends. We hold that he failed to prove that he had unreported
gross receipts of less than $345,172.
2. Whether petitioner had costs of goods sold of
$568,937.79 in 1993, $504,199.79 in 1994, and $560,235.41 in
1995, as petitioner contends, or $74,012 in 1993, $201,963 in
1994, and $101,395 in 1995, as respondent contends. Respondent
determined that petitioner’s costs of goods sold were $199,073 in
1993, $213,564 in 1994, and $166,142 in 1995. We hold that
petitioner failed to prove that his costs of goods sold were more
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Last modified: May 25, 2011