George M. Osserman - Page 2

          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...)           




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