- 2 - Taxable Year Additions to Tax Under Section Penalty Ending Deficiency 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B) 6663 Sept. 30, 1986 $3,022 $1,511 * --- --- --- Sept. 30, 1987 7,542 --- --- $5,657 * --- Sept. 30, 1988 61,367 --- --- 46,025 * --- Sept. 30, 1989 1,284 963 --- --- --- --- Sept. 30, 1990 22,029 --- --- --- --- $16,522 *Plus an addition of 50 percent of the interest due on the deficiency. In the alternative, respondent determined additions to tax and a penalty as follows: Taxable Year Additions to Tax Under Section Penalty Ending 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 6653(a)(2) 6661 6662(a) Sept. 30, 1986 --- --- --- $151 * --- --- Sept. 30, 1987 $1,506 $377 * --- --- --- --- Sept. 30, 1988 5,985 3,068 * --- --- $15,342 --- Sept. 30, 1989 --- --- --- 64 --- --- --- Sept. 30, 1990 --- --- --- --- --- --- $4,406 *Plus an addition of 50 percent of the interest due on the deficiency. Respondent determined deficiencies in Federal income taxes, additions to tax, and penalties for petitioners Frederick Malcolm Sutton and Carolyn P. Sutton as follows: Additions to Tax Under Section Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 1986 $25,141 --- $8 1 --- 1987 48,241 $1,182 496 2 --- 1988 31,139 841 --- --- $368 1989 24,860 6,354 --- --- --- 1990 23,716 5,947 --- --- --- Additions to Tax Under Section Penalty Year 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6661 6663 1986 $18,742 3 --- --- --- 1987 29,787 4 --- $3,597 --- 1988 --- --- $18,590 2,651 --- 1989 --- --- --- --- $15,905 1990 --- --- --- --- 17,787 1 Plus an addition of 50 percent of the interest due on $103. 2 Plus an addition of 50 percent of the interest due on $5,309. 3 Plus an addition of 50 percent of the interest due on $24,989. 4 Plus an addition of 50 percent of the interest due on $38,317. In the alternative, respondent determined additions to tax and penalties as follows: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