- 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