M.S. Food Stores, Inc. - Page 2

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               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:                                                                                        












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