- 3 - Wheaton is an innocent spouse within the meaning of section 6013(e). On that basis, respondent has conceded all deficiencies in income tax, additions to tax, and penalties determined with respect to Mary Wheaton. We accept respondent’s concession and shall enter decisions accordingly. Respondent asks that we enter decisions with respect to petitioners Dorchester Industries Inc. (Dorchester) and Frank Wheaton, Jr. (Frank Wheaton), based on a settlement agreement that respondent claims those petitioners entered into on November 6, 1995. We must determine whether Dorchester and Frank Wheaton did, in fact, enter into such an agreement and, if so, the consequence thereof. Respondent asks that we enter decisions with respect to Dorchester and Frank Wheaton as follows: Docket No. 20515-93 (Dorchester Industries) Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(b)(1) 6653(b)(2) 6661 1981 $92,643 $46,322 None None 1982 89,411 44,706 1 None 1985 230,360 115,180 1 $57,590 1 The addition to tax under I.R.C. sec. 6653(b)(2) is 50 percent of the interest payable under I.R.C. sec. 6601 with respect to the portion of the underpayment which is attributable to fraud, which is the entire deficiency for each of the taxable years 1982 and 1985. Additions to Tax Sec. Sec. Year Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 1986 $1,376 $1,032 1 1 The addition to tax under I.R.C. sec. 6653(b)(1)(B) is 50 percent of the interest payable under I.R.C. sec. 6601 with respect to the portion of the underpayment which is attributablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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