- -2
Additions to Tax
Tax year Sec. Secs. 6653(a)(1)(A)/ Sec. Sec.
ended Deficiency 6651(a) 6653(a) 6653(a)(1)(B) 6661(a)
1/31/88 $145,156 $36,289 $7,258 1 $36,289
1/31/89 289,298 72,325 14,465 -0- 72,325
1 Plus 50% of the interest that is computed on $145,156 for the
taxable year ended Jan. 31, 1988, at the time of assessment and/or
payment of tax.
Tax year Addition to Tax Penalty
ended Deficiency Sec. 6651(a) Sec. 6662(a)
1/31/90 $490,772 $122,693 $98,154
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, unless otherwise
indicated.
Some of the issues raised by the pleadings have been
disposed of by agreement of the parties (including all issues
pertaining to the taxable year ended January 31, 1988 (fiscal
year 1988)), leaving for decision the amount of customs duties,
freight charges, and related fees paid by petitioner with respect
to its goods purchased for sale during each of the years here in
issue, which, when added to the agreed cost of purchases other
than these charges, results in cost of the goods purchased. The
parties agree as to whether the additions to tax and penalty
apply to petitioner and that the amount of such additions to tax
and penalty will be computed under Rule 155.
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Last modified: May 25, 2011