Eric Wynn - Page 2

                                        - 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;            





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