- 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