- 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 reportPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011