- 2 - willful failure to file a return for 1987, does not subject him to double jeopardy in violation of the Fifth Amendment. Tristan P. Junius, for petitioner. Loren B. Mark, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: In the notice of deficiency, respondent determined that petitioner is liable for additions to tax as follows: Additions to Tax Sec. Sec. Sec. Sec. Sec. Year 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B) 6654 1985 $6,677 1 -- -- $706 1986 -- -- $13,206 2 851 1987 -- -- 3,952 3 106 1 Fifty percent of the interest due on the $13,354 underpayment due to fraud. 2 Fifty percent of the interest due on the $17,608 underpayment due to fraud. 3 Fifty percent of the interest due on the $5,269 underpayment due to fraud. After concessions,1 the issues for decision are: 1. Whether petitioner is liable for additions to tax for fraud under section 6653(b) for 1985, 1986, and 1987. We hold that he is. 1 Petitioner concedes that he is liable for the addition to tax for failure to pay estimated tax under sec. 6654 for 1985, 1986, and 1987.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