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admissions served by respondent under Rule 90(c). Petitioner
resided in Lakewood, Colorado, at the time his petition was
filed.
Background
Respondent determined deficiencies in and additions to tax
as follows:
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1)1 6654
1990 $2,269 $1,632 $143
1991 27,458 20,357 1,559
1992 5,998 4,496 260
1Respondent, in the Amended Answer to Amended
Petition, alleged that petitioner is liable for additions to
tax for fraud under sec. 6651(f) for 1990, 1991, and 1992.
Respondent relies on the additions to tax determined in the
notice of deficiency under sec. 6651(a)(1) as an alternative
position, if we find that petitioner is not liable for
additions to tax for fraud under sec. 6651(f).
Petitioner worked as an insurance agent for the Prudential
Life Insurance Company (Prudential) during 1990, 1991, and 1992.
Prudential employed him to sell insurance and annuities to
Prudential clients but did not authorize him to sell securities.
In his capacity as a Prudential insurance agent, petitioner
convinced Prudential clients to cancel their Prudential annuities
and transfer the proceeds to another company, named Project
Input, Inc., which petitioner alleged was sponsored by
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