- 2 -
Additions to Tax
Sec. 6653 Sec. 6653 Sec. 6653 Sec. 6653 Sec.
Year Deficiency (b)(1)1(b)(2) (b)(1)(A)1(b)(1)(B) 6654
1982 $3,323 $1,662 2 --- --- $85
1983 4,336 2,168 2 --- --- 266
1984 1,291 646 2 --- --- 52
1985 3,944 1,972 2 --- --- 222
1986 4,089 --- --- $3,067 2 198
1987 3,685 --- --- 2,764 2 200
1988 2,427 1,820 --- --- --- 153
1 In the alternative to the additions to tax for fraud, respondent determined additions to tax
under secs. 6651(a)(1) and 6653(a)(1) and (2) for all years at issue.
2 50 percent of the interest payable under sec. 6601 for the portion of the underpayment due to
fraud.
Respondent moves for summary judgment as to: (1) The
deficiencies and the additions to tax under section 6654 for
failure to pay estimated tax; and (2) the additions to tax for
fraud under the applicable provisions of section 6653(b) for all
years at issue.2
Background
Petitioner filed a timely petition stating, inter alia, that
"Without a grant of immunity, Petitioner is prevented from
submitting financial information sufficient to refute the taxable
income determined by Respondent lest it be used against him in a
civil or criminal matter". The petition then discusses the Fifth
Amendment to the Constitution and certain cases interpreting that
Amendment.
Respondent filed a timely answer, affirmatively alleging
fraud for all of the years at issue. Petitioner did not file a
2 Respondent's motion for summary judgment does not address
the secs. 6651(a)(1) and 6653(a)(1) and (2) additions to tax for
failure to timely file and for negligence, respectively, which
were determined as an alternative to fraud in the notice of
deficiency for all years and asserted in the answer for taxable
years 1982 and 1983. We do not reach those issues.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011