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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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