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1984, 1985, 1986, and 1987. Respondent determined that the
entire deficiencies, including the portions attributable to self-
employment tax, were subject to the additions to tax. Section
6653(b)(1), applicable to petitioner's 1984 and 1985 returns,
provides for an addition to tax equal to 50 percent of an
underpayment of tax where any part of the underpayment is due to
fraud. Section 6653(b)(1)(A), applicable to petitioner's 1986
and 1987 returns, provides for an addition to tax equal to 75
percent of the portion of the underpayment attributable to fraud.
Section 6653(b)(2), applicable to petitioner's 1984 and 1985
returns, provides for an addition to tax equal to 50 percent of
the interest payable under section 6601 with respect to the
portion of the underpayment attributable to fraud. Section
6653(b)(1)(B), applicable to petitioner's 1986 and 1987 returns,
provides for an addition to tax equal to 50 percent of the
interest payable under section 6601 with respect to the portion
of the underpayment attributable to fraud. Section 6653(b)(2),
applicable to petitioner's 1986 and 1987 returns, provides that
where the Commissioner establishes that any portion of an
underpayment is attributable to fraud, the entire underpayment is
treated as attributable to fraud except to the extent the
taxpayer proves otherwise.
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Last modified: May 25, 2011