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Additions to Tax
Secs. Secs.
TYE Sec. 6653(a)(1)/ 6653(a)(2)/ Sec.
April 30 Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661
1986 $214,988 $53,747 $10,749 1 $53,747
1987 238,492 59,623 11,925 1 59,623
1988 266,342 66,585 13,317 1 66,585
1989 239,264 59,816 11,963 1 59,816
Additions to Tax and Penalties
TYE Sec. Sec. Sec. Secs.
July 31 Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661/6662
1989 $57,636 $14,409 $2,882 1 $14,409
1990 180,366 45,901 - - 36,073
1991 155,345 38,836 - - 31,069
1 50 percent of the interest due on the deficiency.
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.
The issues to be decided are:
1. Whether the period of limitations on assessment and
collection had expired with respect to certain of the taxable
periods in issue at the time respondent sent to petitioner the
statutory notice of deficiency in issue in the instant case;
2. whether income generated by petitioner's solicitation
program for its yearbook is unrelated business income subject to
tax pursuant to section 511 for the taxable periods in issue; and
3. whether petitioner is liable for additions to tax
pursuant to sections 6651(a)(1), 6653(a)(1) and (2),
6653(a)(1)(A) and (B), and 6661(a), and penalties pursuant to
section 6662(a) for certain of the taxable periods in issue.
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Last modified: May 25, 2011