Leslie R. Barth - Page 2

                                                - 2 -                                                   
            Additions to Tax                                                                            
            Year          Deficiency          Sec. 6653(b)                                              
            1976           $136,503             $68,252                                                 
            1978            109,645              55,317                                                 
            1979            173,243              86,622                                                 
            1980            191,834              95,917                                                 

            In a separate statutory notice sent March 7, 1991, to petitioner,                           
            respondent determined a deficiency of $152,448 in petitioner's                              
            Federal income taxes and additions to tax of $76,244 under                                  
            section 6653(b) and $5,425 under section 6654 for 1977.  Unless                             
            otherwise indicated, all section references are to the Internal                             
            Revenue Code in effect for the years in issue, and all Rule                                 
            references are to the Tax Court Rules of Practice and Procedure.                            
                  Petitioner and Ms. Barth filed separate petitions.  Her case                          
            was docketed as No. 11150-91.  After a consolidated trial,                                  
            respondent entered into a stipulated decision with Ms. Barth in                             
            which it was agreed that there are no deficiencies in or                                    
            additions to tax due from her.  The issue remaining for decision                            
            is whether petitioner is liable for the additions to tax for                                
            fraud.  The deficiencies and the addition to tax under section                              
            6654 determined by respondent are decided against petitioner by                             
            reason of his failure properly to prosecute this case; the                                  
            reasons for that action are discussed below.                                                

                                          FINDINGS OF FACT                                              
                  Some of the facts have been stipulated, and the stipulated                            
            facts are incorporated in our findings by this reference.                                   

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