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Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6653(b)(2) 6653(b)(1)(B) 6654(a)
1983 $13,219 $6,610 -- 50% of the -- $808
interest due
on $13,219
1984 13,333 6,667 -- 50% of the -- 838
interest due
on $13,333
1985 8,435 4,218 -- 50% of the -- 484
interest due
on $8,435
1986 4,787 -- $3,590 -- 50% of the 146
interest due
on 4,787
In the alternative to her determination that petitioner is
liable for additions to tax for fraud under section 6653,
respondent determined that petitioner is liable for various
additions to tax under section 6651(a)(1), section 6653(a)(1) and
(2), and section 6653(a)(1)(A) and (B) for the taxable years in
issue.
Petitioner filed a petition for redetermination with the
Court disputing the deficiencies and the additions to tax
determined by respondent in the notice of deficiency. Respondent
filed an answer to the petition, including therein affirmative
allegations as follows: (1) Petitioner is liable for the
additions to tax for fraud for each of the taxable years in
issue; and (2) the doctrine of collateral estoppel applies to
preclude petitioner from contesting his liability for the
additions to tax for fraud under section 6653(b)(1) and (2) for
the taxable year 1984. Thereafter, petitioner filed a reply to
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