- 4 -
MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined deficiencies in
Federal individual income tax, deficiencies in Federal excise tax
under section 49731 (excess I.R.A. contributions), and additions
to tax under sections 6653(b) (fraud) and 6661 (substantial
understatement of income tax) against petitioner as follows:
Deficiency Additions to Tax
Sec.6653 Sec.6653 Sec.6653 Sec.6653
Year Income Tax Excise Tax (b)(1)(b)(2) (b)(1)(A) (b)(1)(B) Sec. 6661
1983 $12,740 $105 $6,370 1 -- -- --
1984 15,917 210 7,959 2 -- -- --
1985 14,924 315 7,462 3 -- -- $3,652
1986 6,400 -- -- -- $4,800 4 --
1987 4,778 315 -- -- 221 5 --
1988 2,886 -- -- -- -- -- --
1 50 percent of the interest due on $12,635.
2 50 percent of the interest due on $3,856.
3 50 percent of the interest due on $14,609.
4 50 percent of the interest due on $6,400.
5 50 percent of the interest due on $294.
Respondent determined in the alternative that, if petitioner
is not liable for part or all of the additions to tax for fraud
for 1986, then petitioner is liable for negligence additions to
tax under subparagraphs (A) and (B) of section 6653(a)(1).
Docket No. 20526-90 deals with 1986, a joint tax return
year. Docket No. 14364-91 deals with 1983, 1984, 1985, and 1987,
1 Unless indicated otherwise, all section references are
to sections of the Internal Revenue Code of 1954, or the Internal
Revenue Code of 1986, as in effect for the respective years in
issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011