Additions to tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(1)(A) 6653(a)(1)(B)
1982 $20,694 -- -- --
1983 23,054 -- -- --
1984 21,788 -- -- --
1987 2,694 -- $135 1
1988 590 $30 -- --
1989 542 -- -- --
Sec. Sec. Sec.
Year 6653(b)(1) 6653(b)(2) 6661(a)
1982 $10,347 2 $5,174
1983 11,527 3 5,764
1984 10,894 4 5,447
1987 -- -- --
1988 -- -- --
1989 -- -- --
1 50 percent of the interest due on $2,694.
2 50 percent of the interest due on $16,124.
3 50 percent of the interest due on $18,722.
4 50 percent of the interest due on $14,437.
The only issue in controversy is whether any part of the
underpayment of tax for the calendar years 1982, 1983, and 1984,
was due to fraud with the intent to evade tax. Petitioner lists
as a further issue whether the assessment and collection of a
deficiency is barred by section 6501(a)1 for the years 1982,
1983, and 1984. Respondent on brief concedes that absent a
showing of fraud on the part of petitioner with respect to any
one of these years, assessment and collection of any tax for that
year is barred by the period of limitations, and petitioner
recognizes that if fraud is shown the period of limitations has
1 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, unless otherwise
indicated.
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Last modified: May 25, 2011