James Alan Price - Page 2

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               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.                                                             




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