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Additions to Tax
Year Deficiency Sec. 6653(b) Sec. 6653(b)(1) Sec. 6653(b)(2)
1980 $3,360 $1,680 -- --
1981 3,431 1,716 -- --
1982 5,209 -- $2,605 1
1983 4,823 -- 2,412 2
150 percent of the interest due on $5,209.
250 percent of the interest due on $4,823.
The issues for decision are:
(1) Whether petitioner is entitled to deduct various
Schedule C expenses for each taxable year at issue. We hold that
he is not.
(2) Whether petitioner is entitled to an investment tax
credit for taxable year 1982. We hold that he is not.
(3) Whether petitioner is liable for the addition to tax
under section 6653(b), for taxable years 1980 and 1981, and
section 6653(b)(1) and (2), for taxable years 1982 and 1983. We
hold that he is.
(4) Whether the period of limitations has expired for
assessment and collection of the deficiencies in and additions to
tax for each taxable year at issue. We hold that it has not.
(5) Whether the equitable doctrine of laches bars assessment
and collection of the deficiencies in and additions to tax for
each taxable year at issue. We hold that it does not.
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Last modified: May 25, 2011