S. Paul and Patricia J. Dubose - Page 2

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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 
          __________________________                                                  
          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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