- 3 - and (6) in the alternative to the fraud additions for 1984, whether petitioner is also liable for an addition to tax for late filing under section 6651(a). We hold that: (1) For 1983, petitioner is collaterally estopped from denying that he committed fraud and is liable for the section 6653(b)(1) fraud addition because of his guilty plea to criminal tax fraud, but that petitioner is not liable for the section 6653(b)(2) fraud addition, except with respect to two items as to which he both pleaded guilty to criminal tax fraud and has otherwise conceded; (2) for 1984, petitioner is not liable for any section 6653(b)(1) or (2) fraud additions; (3) respondent's deficiency determinations are upheld for both 1983 and 1984; (4) petitioner is liable for additions to tax for negligence for 1984; (5) petitioner is liable for additions to tax for substantial understatement for 1983 and 1984; and (6) petitioner is liable for an addition to tax for late filing for 1984. FINDINGS OF FACT The parties have stipulated some of the facts, and the stipulations of fact and attached exhibits are incorporated in this opinion. Petitioner resided in Bradford, Pennsylvania, when he filed his petition. During the years in issue petitioner was the president of Renaissance Enterprises, Inc. (Renaissance). Renaissance wasPage: 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