Judgment on the pleadings and matters deemed admitted pursuant to
Rule 90(c). Petitioner has not responded to the pending motion.
In three notices of deficiency dated August 20, 1986,
respondent determined the following deficiencies in and additions
to petitioner's Federal income tax.
Additions to Tax
Year Deficiency Sec. 6653(b) Sec. 6654(a)
1975 $134,599 $67,299 --
1976 5,050,149 2,525,075 --
1977 7,926,728 3,963,364 $253,655
1978 2,053,106 1,026,553 65,698
1979 1,076,634 538,317 --
1980 441,711 220,855 --
1981 252,288 126,144 --
1982 325,922 -- --
Respondent also determined additions to tax for 1982 in the
amount of $32,592 under section 6661 for substantial
understatement of tax, in the amount of $81,480 under section
6651(a) for failure to timely file, in the amount of $16,296
under section 6653(a)(1) for negligence, and under section
6653(a)(2) in an amount equal to 50 percent of the interest due
on the underpayment attributable to negligence. For the years
1975 through 1982, respondent also determined that interest on
deficiencies accruing after December 31, 1984, would be
calculated at 120 percent of the statutory rate under section
6621(c).2
1(...continued)
Procedure.
2 The notices of deficiency refer to sec. 6621(d). This
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011