- 2 -
Additions to tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)* 6653(b)(2)* 6653(b)(1)(A)* 6653(b)(1)(B)* 6661
1984 $43,179.86 $21,589.93 50% of the -- -- $10,794.97
interest due
on $43,179.86
1985 25,106.76 12,553.38 50% of the -- -- 6,276.69
interest due on
$25,106.76
1986 13,685.74 -- -- $12,207.56 50% of the 3,421.44
interest on
$13,685.74
* Additions to tax for fraud apply only to Benjamin Campfield.
By amendment to answer, respondent asserted the following
increase in the deficiency and additions to tax:
Additions to tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1)* 6653(b)(2)* 6661
1985 $7,393.24 $3,696.62 50% of the $1,848.31
interest due on
$7,393.24
* Additions to tax for fraud apply only to Benjamin Campfield.
After concessions by the parties, the issues for decision
are:
(1) Whether petitioners received unreported income of
$105,205.26 in 1984, $70,214.39 in 1985, and $31,204.29 in 1986.
We hold that they did.
(2) Whether petitioner Benjamin Campfield is liable for
additions to tax for fraud under section 6653(b) for the years in
issue. We hold that he is liable.
Page: 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