- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011