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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 under
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