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Additions to Tax
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
1987 $67,508 $50,631 50 percent of the $16,877
interest due on
$67,508
Petitioner resided in Tigard, Oregon, at the time he
petitioned this Court to redetermine respondent's determination
of a deficiency in his income tax and additions to tax as set out
above. For 1987, respondent determined that petitioner had
$199,796 of unreported income.2
The petitioner herein was the defendant in the criminal case
of United States v. Taylor, which was docketed in the U.S.
District Court for the District of Oregon.
Petitioner was indicted on April 14, 1993, with respect to
the criminal matter. The indictment charged that petitioner
knowingly and willfully attempted to evade Federal income tax for
1987 by filing a false and fraudulent joint Federal income tax
return in violation of section 7201. The indictment charged that
petitioner and Janet Taylor reported taxable income of $0, and a
tax due and owing of $0 on their 1987 joint Federal income tax
return (Form 1040), knowing that their taxable income for 1987
was substantially in excess of such amount.
2 Respondent's motion is for partial summary judgment with
respect to the issue of civil fraud pursuant to sec. 6653(b).
The amount of the underlying deficiency for 1987 remains to be
adjudicated.
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Last modified: May 25, 2011