- 3 -
interest due
on $25,784
interest due
on $28,196
Respondent further determined that part or all of the
underpayments of petitioner's taxes for the taxable years 1982,
1985, and 1986 constitute substantial underpayments attributable
to tax-motivated transactions within the meaning of section
6621(c).
Petitioner and Michelle B. Fox filed a timely joint petition
for redetermination with the Court on August 7, 1989, assigned
docket No. 19361-89, disputing respondent's determinations for
the taxable years 1982 through 1986.2
On April 26, 1990, respondent mailed a statutory notice of
deficiency to petitioner determining a deficiency in and
additions to his Federal income tax for the taxable year 1987 as
follows:
Additions to Tax
Sec. Sec. Sec. Sec.
Deficiency 6653(a) 6653(b) 6654(a) 6659(a)
$32,226 $1,611 $24,170 $1,741 $1,133
Petitioner filed a timely petition for redetermination with the
Court on July 23, 1990, assigned docket No. 16560-90, disputing
respondent's determinations for the taxable year 1987. At the
2 By order dated Apr. 1, 1994, Michelle B. Fox was severed
from docket No. 19361-89, and assigned docket No. 5450-94 in the
name of Michelle B. Fox, a.k.a. Michelle B. Serre.
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