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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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Last modified: May 25, 2011