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Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B)6661(a)
1
1984 $50,374.00 $25,187.00 -- -- $12,593.50
2
1985 15,577.00 7,788.50 -- -- 3,894.25
3
1986 24,752.00 -- -- $18,564.00 6,188.00
150 percent of the interest due on $50,374.
250 percent of the interest due on $15,577.
350 percent of the interest due on $24,752.
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.
After concessions by both parties, we must decide whether
petitioners are liable for the additions to tax for fraud for
1984, 1985, and 1986; whether petitioners are liable for the
additions to tax for substantial understatement of liability for
1984 and 1986; and whether the statute of limitations bars the
assessment of deficiencies and additions to tax for 1984, 1985,
and 1986.
FINDINGS OF FACT
Petitioners C. Richard Roose (Mr. Roose) and Betty B. Roose
(Mrs. Roose) resided in Middlefield, Ohio, when their petition
was filed. During the years in issue and at the time of trial,
petitioners were husband and wife.
Mr. Roose was a pharmacist at all relevant times.
Mrs. Roose also attended pharmacy school but did not complete her
pharmacy degree. As part of their pharmacy school course work,
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