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Additions to Tax
Year Deficiency Sec. 6653(b) Sec. 6661
1985 $163,221 1$ 81,611 $40,805
1986 240,868 1180,651 60,217
1987 39,636 129,727 9,909
1 Plus 50 percent of the interest due on the deficiency.
In the alternative to the additions to tax for fraud, respondent
determined additions to tax for negligence and, for 1987, an
addition to tax for delinquency.
Respondent determined deficiencies in Federal income tax,
additions to tax, and a fraud penalty for petitioner Dennis C.
Gandy as follows:
Additions to Tax Penalty
Year Deficiency Sec. 6653(b) Sec. 6661 Sec. 6663
1988 $ 22,393 $16,795 $5,598 ---
1989 112,205 --- --- $84,154
In the alternative to the fraud addition to tax and penalty,
respondent determined a negligence addition to tax for 1988 and
an accuracy-related penalty under section 6662(a) for 1989. By
amendment to answer, respondent sought revised deficiencies in
income tax, additions to tax, and fraud penalty for petitioner
Dennis C. Gandy as follows:
Additions to Tax Penalty
Year Deficiency Sec. 6653(b) Sec. 6661 Sec. 6663
1988 $27,201 $20,401 $6,800 ---
1989 48,149 --- --- $36,112
Respondent reasserted a negligence addition to tax and penalty in
the alternative to fraud.
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Last modified: May 25, 2011