- 3 -
against petitioner Helen R. DeSantis, said deficiencies and
additions were resolved prior to trial.2
In her amended answer at docket No. 5766-90, respondent
asserted that the deficiencies in and additions to petitioner's
Federal income tax be increased by the following amounts:
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661
1982 $64,429.86 $32,214.93 1 $16,106.97
1983 12,621.33 6,310.67 1 3,154.83
1984 1,066,763.88 533,381.94 1 266,691.47
1 50 percent of the interest due on the deficiency.
The increases to the deficiencies in and additions to tax
are based upon respondent's claim that petitioner fraudulently,
and with the intent to evade tax, failed to report income in the
additional amounts of $128,860.71, $25,237.66, and $2,133,528.76
on his 1982, 1983, and 1984 returns, respectively. Therefore,
the total deficiencies in and additions to tax in dispute with
respect to docket No. 5766-90 are as follows:
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661
1982 $393,679.86 $196,839.93 1 $98,419.97
1983 1,338,683.33 669,341.67 1 334,670.83
1984 1,386,577.88 693,288.94 1 346,644.47
1 50 percent of the interest due on the deficiency
2 Respondent, in a second notice of deficiency dated Apr.
9, 1991, determined additions to tax under secs. 6653(b)(1) and
(2) and 6661 against petitioner Helen R. DeSantis. A timely
petition was filed at docket No. 13108-91. Respondent conceded
the adjustments in this notice of deficiency.
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