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MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notices of deficiency dated March 16,
1994, respondent determined the following deficiencies and
additions to tax with respect to petitioners' Federal income
taxes:
Jimmy Don and Sharon L. Gilchrist, docket No. 10132-94
Additions to Tax
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6653(b)(1) Sec. 6661
1986 $34,608 $25,956 1 -- $8,652
1987 23,644 17,733 2 -- 5,911
1988 38,316 -- -- $28,737 9,579
1 50 percent of the statutory interest due on $34,608.
2 50 percent of the statutory interest due on $23,644.
Door Control Services, Inc., docket Nos. 9936-94 and 10140-94
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6653(b)(1) Sec. 6661
1985 $1,681 $841 -- 1 -- --
1986 31,378 -- $23,534 2 -- $7,845
1987 21,025 -- 15,769 3 -- 5,256
1988 27,336 -- -- -- $20,502 6,834
1 50 percent of the statutory interest due on $1,681.
2 50 percent of the statutory interest due on $31,378.
3 50 percent of the statutory interest due on $21,025.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The only issue in these cases is whether petitioners
are liable for the additions to tax for fraud.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petitions were filed, Jimmy Don and Sharon L.
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