- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011