- 2 - Additions to Tax Year Deficiency Sec. 6661 Sec. 6653 (b) 1980 $113,469 -- $64,650 1981 39,563 -- 28,150 1982 40,360 $10,090 25,125 1983 19,561 4,890 9,781 1984 19,286 4,822 9,643 1985 41,813 10,453 20,907 1986 21,143 5,286 12,907 After concessions, the issues for decision are: (1) Whether certain deposits to a foreign bank account constitute unreported income to petitioner. We hold that they do. (2) Whether petitioner is liable for additions to tax for fraud under section 6653(b) for 1980 and 1981, under section 6653(b)(1) and (2) for 1982 through 1985, and under section 6653(b)(1)(A) and (B) for 1986. With respect to taxable years 1980 through 1984, we hold that he is. With respect to taxable years 1985 and 1986, we hold that he is not. (3) Whether petitioner is liable for the addition to tax under section 6661 for a substantial understatement in income tax for taxable years 1982, 1983, 1984, 1985, and 1986. To the extent provided for herein, we hold that he is. (4) Whether the period of limitations has expired for assessment and collection of the deficiencies in and additions to petitioner's Federal income tax for any year at issue. With respect to taxable years 1980 through 1984, we hold that it has not. With respect to taxable years 1985 and 1986, we hold that it has.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011