- 4 - to tax under section 6651(a)(1) for its taxable years ending September 30, 1987, and 1988; (4) whether the corporate petitioner is liable for additions to tax for negligence for its taxable year ending September 30, 1986, under section 6653(a)(1) and (2); for its taxable years ending September 30, 1987, and 1988, under section 6653(a)(1)(A) and (B); and for its taxable year ending September 30, 1989, under section 6653(a)(1); and for an accuracy-related penalty for negligence for its taxable year ending September 30, 1990, under section 6662(a); (5) whether the corporate petitioner is liable for an addition to tax under section 6661 for its taxable year ending September 30, 1988; (6) whether petitioners Frederick Malcolm Sutton and Carolyn P. Sutton (the Suttons) had unreported income, in the taxable years 1986, 1987, 1988, and 1990, from rebate and coupon checks diverted from the corporate petitioner; (7) whether the Suttons had additional unreported income, in the taxable years 1986 through 1990, from diverted corporate funds (unexplained bank deposits); (8) whether the Suttons are liable for additions to tax under section 6651(a)(1) for the taxable years 1987 through 1990; (9) whether the Suttons are liable for additions to tax for negligence for the taxable years 1986 and 1987 under section 6653(a)(1)(A) and (B); and for the taxable year 1988 underPage: 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