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Rehtorik’s (petitioner’s) individual Federal income taxes and
additions to tax for 1986 and 1987, as follows:
Michael W. and Barbara B. Rehtorik
Additions To Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6661
1984 $131,360 $65,680 * $32,840
1985 165,695 82,848 * 41,424
* 50 percent of interest due on amount of deficiency
attributable to fraud.
Michael W. Rehtorik
Year Deficiency
1986 $3,337
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A)6653(a)(1)(B)
1987 $125,206 $1,370 $1,346 *
Sec. Sec. Sec.
6653(b)(1)(A) 6653(b)(1)(B) 6661
$73,715 ** $31,302
* 50 percent of interest due on amount of deficiency
attributable to negligence.
** 50 percent of interest due on amount of deficiency
attributable to fraud.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After settlement, the primary issues for decision in these
consolidated cases are: (1) Whether petitioner is liable for the
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Last modified: May 25, 2011