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Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b) 6653(b)(1) 6653(b)(2) 6661
1981 $ 202,543 $101,272 --- --- ---
1982 1,648,220 --- $ 824,110 * $409,875
1983 3,038,233 --- 1,519,117 * 746,901
1984 768,593 --- 384,297 * 192,148
* 50 percent of interest due on portion of underpayment
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.
Petitioner, in general, does not contest the correctness of
respondent's determinations regarding the amounts of the income
tax deficiencies, nor the additions to tax for fraud and for
substantial underpayment of income tax. Petitioner, however,
contends that she qualifies as an innocent spouse with regard to
the income tax deficiencies and to all additions to tax.
Alternatively, petitioner contends that the fraud on which the
additions to tax under section 6653 are based is attributable
solely to Martin.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Martin and petitioner filed separate petitions regarding the
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