Ted W. Gleave - Page 3

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               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.                                             


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