T.C. Memo. 1996-500
UNITED STATES TAX COURT
KONDAMODI S. RAO AND B. SATYAVENI RAO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4468-94. Filed November 6, 1996.
Sanford Amdur, for petitioners.
Robert W. Mopsick, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined deficiencies in and
additions to petitioners' Federal income tax as follows:
Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec.
6653 6653 6653 6653 6653 6653 Sec.
Year Deficiency (a)(1) (a)(1)(A) (a)(1)(B) (b)(1) (b)(1)(A) (b)(1)(B) 6661
1986 $65,075 --- $2,025 * --- $18,434 ** $16,269
1987 33,648 --- 453 * --- 18,448 ** 8,412
1988 24,644 $412 --- --- $12,296 --- --- 6,161
* 50 percent of the interest due on the portion of the underpayment due to negligence.
** 50 percent of the interest due on the portion of the underpayment due to fraud.
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