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Additions to Tax and Penalties, I.R.C.
Sec. 6653(b)(1) or
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6663(a)
1986 $ 59,557 $ 39,320 1 --
1987 228,770 168,588 1 --
1988 18,118 11,724 -- --
1989 23,688 -- -- $15,733
1990 14,834 -- -- 11,126
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1 50% of the interest due on the portion of the underpayment that is
attributable to fraud.
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. Prior to trial, petitioner Patricia J. Dubose
(Mrs. Dubose) and respondent entered into an agreement in which
Mrs. Dubose conceded the deficiencies determined by respondent
and respondent conceded that Mrs. Dubose is not liable for the
additions to tax or penalties for fraud. S. Paul Dubose
(petitioner) failed to appear for trial, and respondent orally
moved to dismiss his petition for lack of prosecution as to those
issues upon which petitioner has the burden of proof. Respondent
proceeded to present evidence that the deficiencies for the years
in issue are due to fraud on the part of petitioner.
FINDINGS OF FACT
Petitioners resided in Blanco, Texas, at the time that they
filed their petition. Petitioners were married and filed joint
Federal income tax returns for each of the years in issue.
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Last modified: May 25, 2011