- 2 - Additions to Tax Year Deficiency Sec. 6653(b)(1)1 Sec. 6653(b)(2) Sec. 6661 1984 $13,599 $ 6,780 * $ 3,390 1985 11,358 5,679 * 2,840 * 50 percent of the interest due on the deficiency in tax After concessions by the parties, the sole issue for decision is whether petitioner, who failed to report embezzlement income, is liable for additions to tax for fraud. We hold she is not. FINDINGS OF FACT Some of the facts have been stipulated and, with one exception, are so found. The stipulated facts and the accompanying exhibits are incorporated into our findings by this reference. Petitioner resided in Duluth, Georgia, at the time of filing her petition in this case. For the taxable years 1984 and 1985, petitioner timely filed Federal income tax returns, Forms 1040, as a head of household, and as married filing jointly, respectively.2 On her tax returns for 1984 and 1985, petitioner reported total income of $14,972 and $109,356, respectively. Respondent determined deficiencies 1 All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. All dollar amounts are rounded to the nearest dollar, unless otherwise indicated. 2 In February of 1985, petitioner married her second husband, Byron K. Griffith, and the couple filed a joint return for that year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011