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Additions to Tax
Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) 1Sec. 6653(g)
$343,253 $15,446 $9,352 $187
1The statutory notice of deficiency and all documents filed
by the parties have inadvertently referred to this addition to
tax as imposed by sec. 6653(g). The addition to tax is
actually imposed by sec. 6653(a)(1). Sec. 6653(g) merely
prescribes special rules for the application of the addition to
tax for underpayments resulting from the failure to show income
reported on Forms 1099.
The issues for decision are: (1) Whether petitioner's
receipt of money in exchange for his stock in Farmingdale Swim
and Recreation Club, Inc. (FSRC), constituted a liquidating
distribution; (2) whether petitioner had unreported interest
income of $13,370; (3) whether petitioner is liable for additions
to tax under section 6651(a)(1)1 and (2) for failure to file a
timely 1988 Federal income tax return and failure to timely pay
his 1988 income tax liability; and (4) whether petitioner is
liable for an addition to tax for negligence under section
6653(a)(1).
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011