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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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