John Devlin - Page 2

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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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