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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.
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Last modified: May 25, 2011