- 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 $2,884Page: 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