- 2 -
3. Held, further, amounts of deficiencies
redetermined.
Donald L. Summer, for petitioners.
Jerome F. Warner and Matthew I. Root, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined deficiencies in
Federal individual and corporate income tax and additions to tax
under section 6653(b)1 (fraud) against petitioners as follows:
Additions to tax
Sec. Sec. Sec.
Petitioner Year1 Deficiency2 6653(b)6653(b)(1) 6653(b)(2)
Ted W. Gleave 1980 $50,619.25 $25,309.63 --- ---
Dkt. No. 3586-87 1981 266,339.71 133,169.86 --- ---
1982 52,610.08 --- $26,305.04 3
747 Kenmore 1980 2,972.00 1,486.00 --- ---
Ave. Inc. 1981 317,523.17 158,761.59 --- ---
Dkt. No. 10512-89 1982 191,446.02 ---95,723.01 3
1 Calendar years for the individual petitioner and fiscal years ending Aug.
31 for the corporate petitioner.
2 Of these amounts in docket No. 3586-87, $2,097.90 for 1980, $2,762.10 for
1981, and $3,029.40 for 1982 are self-employment taxes under ch. 2; the
remainder are income taxes under ch. 1.
3 50 percent of the interest due on the entire deficiency.
1 The substance of sec. 6653(b) as in effect for 1980 and
1981, and sec. 6653(b)(1) as in effect for 1982 appears in secs.
6651(f) and 6663 of present law.
Unless indicated otherwise, all section and chapter
references are to sections and chapters of the Internal Revenue
Code of 1954 as in effect for the years in issue.
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