- 3 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011