- 2 -
DeCaprio be held in default (respondent's motion).
Respondent determined the following deficiencies in, and
additions to, petitioner Ferdinand DeCaprio's Federal income
tax:2
Additions to Tax
Section Section Section Section Section
Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(2) 6661
1983 $22,380 $11,190 -- -- * $5,595
1984 7,474 3,737 -- -- * 1,869
1985 9,587 4,794 -- -- * 2,397
1986 18,446 -- $13,835 * -- 4,612
* 50 percent of the interest due on the portion of the underpayment attributable
to fraud. Respondent determined that the entire underpayment for each of the
years at issue was due to fraud.
In respondent's motion, respondent asks us to take account
of certain concessions by respondent and to find the following
deficiencies in, and additions to, petitioner's Federal income
tax:
Additions to Tax
Section Section Section Section Section
Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(2) 6661
1983 $17,045 $8,523 -- -- * $4,261
1984 4,553 2,277 -- -- * -0-
1985 6,452 3,226 -- -- * 1,613
1986 -0- -- -0- -0- -- -0-
2 In the notice of deficiency (notice) issued to both Ferdinand
DeCaprio and Claire DeCaprio, respondent determined the same
deficiencies in, but not the same additions to, Claire DeCaprio's
Federal income tax. That is to say, while respondent determined
deficiencies in petitioner Claire DeCaprio's Federal income tax
for 1983 through 1986 in the amounts of $22,380, $7,474, $9,587,
and $18,446, respectively, she determined additions to petitioner
Claire DeCaprio's Federal income tax only under sec. 6661 for
each of those years in the amounts of $5,595, $1,869, $2,397, and
$4,612, respectively. Petitioner Claire DeCaprio and respondent
entered into, and filed with the Court, a stipulation of settled
issues disposing of all issues as to petitioner Claire DeCaprio.
Hereinafter, all references to petitioner shall be to petitioner
Ferdinand DeCaprio.
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