- 2 - 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011