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Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B) 6661(a)
1984 $78,807.11 $39,403.56 1 -- -- $19,701.78
1985 41,092.63 20,546.32 2 -- -- 10,273.16
1986 36,949.80 -- -- $27,712.35 3 9,237.45
1987 16,621.39 -- -- 12,466.04 4 4,155.35
1 50 percent of the statutory interest on $78,807.11, computed from Apr. 15, 1985, to the
earlier of the date of assessment or the date of payment.
2 50 percent of the statutory interest on $41,092.63, computed from Apr. 15, 1986, to the
earlier of the date of assessment or the date of payment.
3 50 percent of the statutory interest on $36,949.80, computed from Apr. 15, 1987, to the
earlier of the date of assessment or the date of payment.
4 50 percent of the statutory interest on $16,621.39, computed from Apr. 15, 1988, to the
earlier of the date of assessment or the date of payment.
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 for decision are as follows:
1. Whether petitioner failed to report income in 1984, 1985,
1986, and 1987. We hold that he failed to report income.
2. Whether petitioner, pursuant to section 1401, is liable
for self-employment tax. We hold that he is liable.
3. Whether petitioner, pursuant to section 6653(b), is
liable for additions to tax for fraud. We hold that he is liable
to the extent stated herein.
4. Whether petitioner, pursuant to section 6661(a), is
liable for additions to tax for substantial understatements of
tax. We hold that he is liable.
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Last modified: May 25, 2011