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Additions to Tax
Year Deficiency Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1979 $1,476 $74 --- --- $443.00
1980 3,402 170 --- --- 1,021.00
1981 3,532 --- $177.00 1 1,060.00
1982 7,975 --- 398.75 1 1,766.10
1983 9,428 --- 471.40 1 1,677.60
1984 2,472 --- 123.60 1 741.60
1 50 percent of the interest due on the portion of the underpayment
attributable to negligence.
After concessions, the sole issue for decision is whether
petitioner is liable for the applicable additions to tax under
section 6653(a) and under section 6653(a)(1) and (2) in the
years at issue.
All section references are to the Internal Revenue Code as
in effect for the years under consideration. All Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Detroit, Michigan, at the time the petition was filed in this
case.
Petitioner received a bachelor of arts degree from Alabama
A & M University in 1967 and a master's of business
administration (M.B.A.) with concentrations in finance and
management from Indiana University in 1970. After receiving his
M.B.A. degree, petitioner was employed by the Ford Motor Co.,
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