- 2 - Respondent determined deficiencies in petitioners' Federal income taxes, additions to tax, and penalties for the years 1991, 1992, and 1993 as follows: Petitioner husband: Additions to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6651(f) Sec. 6663(a) 1991 $4,718 $100 -- $3,538 1992 5,419 -- $430 -- 1993 4,707 -- 124 -- Petitioner wife: Additions to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6651(f) Sec. 6663(a) 1991 $4,713 $100 -- $3,535 1992 5,394 -- $411 -- 1993 4,707 -- 124 -- The issues for decision are: (1) Whether petitioners failed to report income in amounts determined by respondent for the years 1991, 1992, and 1993; (2) whether petitioners are liable for the section 6651(a)(1) addition to tax for 1991; (3) whether petitioners are liable for the section 6651(f) additions to tax for 1992 and 1993 for failure to file due to willful intent to evade income taxes; (4) whether, in the event it is decided that the failure to timely file was not due to willful intent to evade income taxes, petitioners are liable for the delinquency penalty under section 6651(a)(1) for 1992 and 1993; (5) whether petitioners are liable for the section 6663(a) fraud penalty for 1991; and (6) whether, in the event it is decided thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011