Frederick M. Fox - Page 4

                                        - 4 -                                         
          time that he filed his petitions, petitioner resided at San Juan            
          Capistrano, California.                                                     
               In the answer to the petition in docket No. 16560-90, which            
          respondent filed on September 21, 1990, it is asserted that the             
          statutory notice of deficiency incorrectly identified the                   
          additions to tax for negligence and fraud.  The correct                     
          references are as follows:                                                  
               Sec.             Sec.           Sec.            Sec.                   
          6653(a)(1)(A)   6653(a)(1)(B)   6653(b)(1)(A)   6653(b)(1)(B)               
          $1,611             1           $24,170            2                         
               1  50 percent of the interest due on the portion of the                
          underpayment due to negligence or intentional disregard of rules            
          and regulations.                                                            
               2  50 percent of the interest due on that portion of the               
          underpayment due to fraud.                                                  
          The answer further asserts that the only portion of the                     
          underpayment due to fraud is that portion relating to unreported            
          W-2 wages of $135,618.  The remaining portion of the underpayment           
          is due to negligence.  In the alternative, respondent has                   
          asserted that if the Court does not find that the portion of the            
          underpayment from the unreported wages is attributable to fraud,            
          then it is attributable to negligence or intentional disregard of           
          rules and regulations.                                                      
          The deficiencies and additions to tax set forth above are                   
          based on a number of adjustments, the most substantial of which             
          is respondent's determination that petitioner failed to report              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011