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Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(f) 6653(b)(1)(A) 6653(b)(1) 6654
1986 $77,772 -0- 1$58,329 -0- $3,762
1988 75,917 -0- -0- $56,938 4,855
1989 90,355 $67,766 -0- -0- 6,110
1990 79,886 59,915 -0- -0- 5,261
1991 96,053 72,040 -0- -0- 5,526
1 In addition, with respect to the taxable year 1986, respondent has
determined an addition to tax pursuant to sec. 6653(b)(1)(B) in an amount
equal to 50 percent of the interest due on the underpayment attributable to
fraud.
Respondent also determined a deficiency and additions to tax
against petitioners, jointly, for the 1987 taxable year.
Additions to Tax
Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6661
1987 $93,523 1$70,142 $23,381
1 Respondent also determined, with respect to the taxable
year 1987, an addition to tax pursuant to sec. 6653(b)(1)(B) in an
amount equal to 50 percent of the interest due on the underpayment
attributable to fraud.
Finally, as an alternative position, respondent determined that
if the Court does not find liability for sections 6651(f) and/or
6653(b), then the delinquency addition to tax should apply in
each year and the negligence addition should also be applied for
1986, 1987, and 1988.
After concessions, the remaining issues for our
consideration are: (1) Whether petitioner Richard Nelon is
liable for additions to tax for fraud under section
6653(b)(1)(A)1 and (B) for the taxable years 1986 and 1987 and
1 Section references are to the Internal Revenue Code in
effect for the taxable years at issue. Rule references are to
this Court’s Rules of Practice and Procedure.
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