Reaves Livestock, Inc., et al. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COLVIN, Judge:  Respondent determined deficiencies and                 
          additions to tax in petitioners' Federal income tax as follows:             
                               Reaves Livestock, Inc.                                 
                                        Additions to Tax                              
          Year Deficiency  Sec. 6653(b)(1)  Sec. 6653(b)(1)(A) Sec. 6661              
          1984  $39,374      $28,835                        $14,418                   
          1985   79,218       42,459                        21,229                    
          1986   95,420                      $91,216        30,405                    
          1987   85,092                      74,947         24,982                    
               Respondent also determined that Reaves Livestock, Inc.                 
          (Reaves Livestock) is liable for additions to tax for fraud of 50           
          percent of the interest due on $57,670 for 1984 and $84,918 for             
          1985 under section 6653(b)(2), and 50 percent of the interest due           
          on $121,621 for 1986 and $99,929 for 1987 under section                     
          6653(b)(1)(B).                                                              
                        George K. Reaves and Linda L. Reaves                          
                                       Additions to Tax                               
          Year Deficiency  Sec. 6653(b)(1)  Sec. 6653(b)(1)(A) Sec. 6661              
          1984  $40,883      $20,552                        $10,221                   
          1985   66,787       34,452                        16,697                    
          1986  130,741                      $98,056      32,685                      
          1987  112,224                      84,168      28,056                       
               Respondent also determined that George K. Reaves (Mr.                  
          Reaves) and Linda L. Reaves (Mrs. Reaves) are liable for                    
          additions to tax for fraud of 50 percent of the interest due on             
          $40,883 for 1984 and $66,787 for 1985 under section 6653(b)(2),             
          and 50 percent of the interest due on $130,741 for 1986 and                 
          $112,224 for 1987 under section 6653(b)(1)(B).                              





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