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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 the
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