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Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(1)(A) 6653(a)(2) 6653(a)(1)(B) 6661
1985 $96,919 $19,480 $4,846 -- 1 -- $24,230
1986 59,044 14,611 -- $2,952 -- 2 14,761
1987 116,370 29,093 -- 5,819 -- 3 28,414
1988 25,576 2,558 1,279 -- -- -- 6,394
1 Fifty percent of the interest due on $96,919
2 Fifty percent of the interest due on $59,044.
3 Fifty percent of the interest due on $113,657.
Pursuant to six stipulations of settled issues, the parties
resolved, by mutual concessions, all substantive issues in this
case and agreed that petitioners are liable for deficiencies in
the amounts of $96,919 for 1985, zero for 1986, $92,439 for 1987,
and $12,544 for 1988. The only issues that remain for decision
concern petitioners' liability for additions to tax, based on the
agreed underpayments for 1985, 1987, and 1988, for failure to
file timely returns under section 6651(a)(1), for negligence or
(intentional) disregard of rules or regulations under section
6653(a), and for substantial understatement of tax under section
6661. We hold petitioners liable for each of the additions to
tax.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
by this reference. At the time the petition was filed,
petitioners resided in Great Neck Estates, New York. All
references to petitioner are to petitioner Stanley Cohen.
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