- 2 -
1. Held: Sanctions imposed; the matters
contained in R's requested admissions are established
for purposes of this case.
2. Held, further: P had unreported taxable
income as determined by R for each of the years in
issue. P is also liable for an addition to tax for
fraud under sec. 6653(b), I.R.C., for each of the years
in issue, an addition to tax for substantial
understatement of income tax under sec. 6661, I.R.C.,
for 1984, and an addition to tax for failure to pay
estimated tax under sec. 6654, I.R.C., for 1986.
James Luther Cochrane, pro se.
Karen N. Sommers, for respondent.
OPINION
RUWE, Judge: Respondent determined deficiencies in and
additions to petitioner's Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661
1983 $3,264 $1,632 50 percent of --
the interest due
on $3,264
1984 6,767 3,384 50 percent of $1,692
the interest due
on $6,767
1985 2,133 1,067 50 percent of --
the interest due
on $2,133
Additions to Tax
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6654
1986 $2,884 $2,163 50 percent of the $139
interest due on
$2,884
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