- 2 -
Docket No. 5943-92
Addition to Tax
Year Deficiency Sec. 6653(b)
1976 $1,448 $724
1977 14,340 7,170
Docket No. 5942-92
Addition to Tax
Year Deficiency Sec. 6653(b)
1978 $74,609 $37,305
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After stipulations by the parties, the remaining issue for
decision is whether additions to tax for fraud under section
6653(b) violate the Double Jeopardy and Excessive Fines Clauses
of the Fifth and Eighth Amendments where petitioner has been
criminally convicted of tax evasion under section 7201 and has
served jail time and paid fines pursuant to those convictions.
Petitioner, John R. Louis, was a resident of Modesto,
California, at the time the petition in this case was filed. He
was the subject of an investigation by a grand jury, based on
information developed by the Criminal Investigation Division of
the IRS.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011