- 3 -
By answer to the petition of Ted W. Gleave, docket No. 3586-
87, respondent asserts as to each of the years in issue, in the
alternative to section 6653(b), additions to tax under sections
6651 (failure to timely file tax returns), and 6653(a)
(negligence, etc.). See secs. 6214(a), 6653(d).
Petitioner Ted W. Gleave is hereinafter sometimes referred
to as Gleave. Petitioner 747 Kenmore Ave., Inc., is hereinafter
sometimes referred to as Kenmore.
The instant cases have been consolidated for trial,
briefing, and opinion.
After concessions by both sides,2 the issues for decision
are as follows:
(1) Whether Gleave is liable for civil fraud additions
to tax under section 6653(b) (for 1980 and 1981), and under
sections 6653(b)(1) and 6653(b)(2) (for 1982) and, as to
section 6653(b)(2), in what amount.
(2) Whether Kenmore is liable for civil fraud
additions to tax under section 6653(b) (for its fiscal 1980
and 1981), and under sections 6653(b)(1) and 6653(b)(2) (for
2 Gleave concedes that he did not file income tax returns
for any of the years in issue. Petitioners concede that certain
of the checks that Kenmore issued are for Gleave’s personal
expenses. Respondent concedes adjustments that, respondent
contends, reduce Gleave’s deficiencies to $26,820.24 for 1980,
$259,373.31 for 1981, and $50,213.68 for 1982; and reduce
Kenmore’s deficiencies to $215,601.05 for its fiscal 1981, and
$155,587.90 for its fiscal 1982. Respondent’s concessions as to
Gleave aggregate almost one-tenth of the amounts determined
against Gleave; those as to Kenmore aggregate more than one-
quarter of the amounts determined against Kenmore. The additions
to tax are reduced accordingly.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011