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
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