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A. Lee Petersen
Addition to Tax
Year Deficiency Sec. 6653(b)
1984 -0- $11,224
1986 -0- 9,074
INI Builders, Inc.
Additions to Tax
Year Ending Deficiency Sec. 6653(b) Sec. 6661
9/30/84 $43,515 $21,758 $10,879
Having declined, because we lack jurisdiction over the
subject matter, to address the argument of A. Lee Petersen
(petitioner) that respondent’s claims against petitioner were
discharged in bankruptcy, we hold that petitioner committed fraud
within the meaning of section 6653(b). Because we dismiss INI
Builders, Inc. (INI), a dissolved corporation, as a party for
lack of jurisdiction, we do not address whether INI is liable for
a deficiency or additions to tax for fraud and substantial
understatement under sections 6653(b) and 6661.
FINDINGS OF FACT
Background
On August 20, 1993, respondent issued notices of deficiency
to petitioner and INI. On November 16, 1993, petitioner timely
filed a petition with this Court on his and INI’s behalf. At the
1(...continued)
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. Dollar amounts have been rounded to the
nearest dollar.
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