- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION PARR, Judge: Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows: Joseph T. and Nancy Walker Docket No. 4923-90 Additions to Tax Year Deficiency Sec. 6653(b)1 1978 $96,900.21 $48,450.11 1979 104,619.49 52,309.75 1980 183,321.39 91,666.07 1981 124,031.84 62,015.92 1 The fraud addition was determined as to Joseph T. Walker only. West Jersey Manufacturing Co., Inc. Docket Nos. 18842-90 and 28294-91 Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6653(a)(1) 6653(a)(2) 6653(b) 6661 3/31/78 $963.00 -- -- $481.50 - 3/31/79 123,397.51 -- -- 60,998.96 - 3/31/80 81,435.75 40,717.87 - -- -- 3/31/81 174,068.45 85,263.85 - -- -- 3/31/82 101,585.07 101,585.07 - -- -- 3/31/83 0.00 $7,286.48 1 $36,432.38 -- 3/31/85 88,180.05 4,409.00 2 -- 22,045.01 150 percent of the interest due on $145,729.51. 250 percent of the interest due on the deficiency. After concessions, the remaining issues we must decide are: (1) Whether respondent's determination with respect to unreported taxable income of petitioner Joseph T. Walker (Mr. Walker), for 1978, 1979, 1980, and 1981, should be reduced to take into account certain alleged additional cash payments Mr. Walker made to two individualsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011