- 2 -
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1987 $25,096 $6,274.00 $1,355
1988 19,548 4,887.00 1,248
1989 28,462 7,116.00 1,926
1990 33,185 8,296.25 2,178
1991 30,884 7,721.00 1,771
This case presents the following issues:
1. Whether petitioner is liable for the deficiencies
determined by respondent. We hold that petitioner is liable.
2. Whether petitioner is liable for additions to tax
pursuant to section 6651(a)(1)1 for failing to file Federal
income tax returns. We hold that petitioner is liable.
3. Whether petitioner is liable for additions to tax
pursuant to section 6654 for failing to make estimated Federal
income tax payments. We hold that petitioner is liable.
4. Whether petitioner has asserted frivolous and groundless
arguments that warrant the imposition of a penalty pursuant to
section 6673. We hold that petitioner has asserted frivolous and
groundless arguments, and the Court shall impose a penalty.
FINDINGS OF FACT
The parties have stipulated all relevant facts, and these
facts are so found.
1Unless 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.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011