- 2 -
1989 --- --- --- --- $22,664
150 percent of the statutory interest applicable on $29,316 and $21,865
for 1986 and 1987, respectively, from the due date of the return to the date
of assessment of the tax or, if earlier, the date of the payment.
All section references are to the Internal Revenue Code in
effect for the years in issue. All Rule references, unless
otherwise indicated, are to the Tax Court Rules of Practice and
Procedure.
Respondent contends that Dr. Kalo (petitioner) fraudulently
and with the intent to evade taxes understated his interest
income from foreign bank accounts for the 1986, 1987, 1988, and
1989 tax years. After concessions,1 the issues for decision are
whether petitioner is liable for additions to tax pursuant to
section 6653(b)(1)(A) and (B) for the 1986 and 1987 tax years and
section 6653(b)(1) for the 1988 tax year and for a penalty
pursuant to section 6663 for the 1989 tax year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners resided in West
Bloomfield, Michigan, at the time they filed their petition.
1 Respondent concedes that Yehiella Kalo is not liable for
the additions to tax and penalty as determined in the statutory
notice of deficiency. Respondent also concedes the deficiency
for the 1986 tax year. Petitioners filed an amended tax return
prior to the issuance of the notice of deficiency reflecting an
underpayment of $29,316 for the 1986 tax year.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011