- 2 - Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(b)(1) 6653(b)(2) 6661 1983 $79,722 $39,861 1 $19,931 1984 39,785 19,982 1 9,946 1 The addition to tax under sec. 6653(b)(2) is 50 percent of the interest payable under sec. 6601 with respect to the portion of the underpayment that is attributable to fraud. 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 has conceded an increased deficiency of $27,199 for 1983, with corresponding additions to tax for fraud under section 6653(b)(1) and (2) and for substantial understatement under section 6661. After other concessions by the parties, the following issues remain for decision: (1) Whether and in what amount petitioner is liable for the fraud additions under section 6653(b)(1) and (2) for 1983; (2) whether and in what amount petitioner is liable for the fraud additions under section 6653(b)(1) and (2) for 1984; (3) whether and in what amounts petitioner had unreported embezzlement income for the years in issue and unreported consulting income for 1984; (4) in the alternative to the fraud additions, whether petitioner is liable for additions to tax for negligence under section 6653(a)(1) and (2) for 1983 and 1984; (5) whether petitioner is liable for the addition to tax for substantial understatement under section 6661 for 1983 and 1984;Page: 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