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Held, further, P H is liable for civil fraud
penalties pursuant to sec. 6663, I.R.C., for 1996 and
1997.
Held, further, P H is liable for an accuracy-
related penalty pursuant to sec. 6662(a), I.R.C., with
respect to that portion of the deficiency for 1996 that
is not attributable to fraud.
Held, further, the statute of limitations does not
bar assessment of liabilities for 1996 and 1997.
Held, further, P W is not entitled to relief
pursuant to sec. 6015, I.R.C., for the years 1996 and
1997.
Robert Alan Jones, for petitioners.
Richard J. Hassebrock and John A. Freeman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined the following
deficiencies and penalties with respect to petitioners’ Federal
income taxes for the 1996 and 1997 taxable years:1
Homer L. Richardson - Docket No. 16794-03
Penalties
Year Deficiency Sec. 6662 Sec. 6663
1996 $164,442 $67.80 $123,077.25
1997 123,848 92,886.00
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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