- 7 - and interposed for an improper purpose), and may invite sanctions. We thus hold that petitioner is estopped from denying, for purposes of this case, that he filed a false and fraudulent Federal income tax return, with the intent to evade income tax for 1987. Finally, because petitioner's fraudulent intent, for purposes of the additions to tax under sections 6653(b)(1)(A) and (B) has been established for 1987, it follows that the assessment and collection of the deficiency in income tax and the additions to tax are not barred by the expiration of the statutory limitation period. Sec. 6501(c)(1). Respondent's motion for partial summary judgment will be granted. To reflect the foregoing, An appropriate order will be issued.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011