- 2 - 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 thePage: 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