- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011