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Additions to Tax
Section Section
Section 6653(b)(1)( 6653(b)(1)( Section Section
Year Deficiency 6653(b)(1)1 A) B) 6653(b)(2) 6654
1983 $8,389 $4,195 -- -- * --
1984 ** 6,412 -- -- * --
1985 ** 7,021 -- -- * --
1986 14,340 -- $10,755 * -- $694
1987 ** -- 17,801 * -- --
1988 28,763 21,572 -- -- -- 1,850
* 50 percent of the interest on the portion of the underpayment attributable to
fraud.
** Previously assessed upon filing of delinquent Federal income tax return
(return).
The issues for decision are:
(1) Is petitioner liable for the deficiencies determined in
the notices of deficiency (notices)? We hold that he is.
(2) Is petitioner liable for the additions to tax for fraud
for the years at issue? We hold that he is.
(3) Is petitioner liable for the additions to tax under
section 6654 for 1986 and 1988? We hold that he is.
Background
This case was submitted on the basis of the facts and
evidence that the Court deemed to be established for purposes of
this case in its Order under Rule 91(f) dated January 10, 1997.
At the time the petition was filed, petitioner resided in
Bethany, Oklahoma.
Petitioner filed a joint return for 1983. He did not
1 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011