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Mr. Riffe and Mrs. Pert filed joint income tax returns from 1986
to 1989.
Respondent determined that Mrs. Pert is liable as a
transferee of the assets of Mr. Riffe for his and Mrs. Pert's
unpaid income tax and interest and Mr. Riffe's additions to tax
from 1986 to 1989. Respondent also determined that Mr. Pert is
liable for Mr. Riffe's and Mrs. Pert's income tax and Mr. Riffe's
additions to tax as a successor transferee of the assets of Mr.
Riffe, or as a transferee of the assets of Mrs. Pert.
Mr. Riffe's and Mrs. Pert's
Unpaid Joint Federal Income Tax Liabilities
Fees and
Tax Period Collection Assessed Payments Unpaid
Ending Tax Costs Interest Made Balance
1986 $37,342 $ 12 $25,158 $43,976 $18,5241
1987 19,991 12 12,885 0 32,888
1988 14,684 0 6,574 5,000 16,260
Total Unpaid Income Tax Liability $67,672
1Respondent determined these amounts without explaining apparent
math discrepancy.
Mr. Riffe's Unpaid Additions to Tax
Tax Substantial
Period Fraud Understatement Negligence Accuracy Total
1986 $42,869 $9,335 $ 0 $ 0 $52,204
1987 0 4,998 7,443 0 12,441
1988 0 3,205 734 0 3,939
1989 0 0 0 3,819 3,819
Total $42,869 $17,538 $8,177 $3,819 $72,403
Mr. Riffe's unpaid income tax from 1986 to 1989 is $140,075.
Mr. Riffe's liability is larger than Mrs. Pert's liability
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Last modified: May 25, 2011