- 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