- 2 - Stanley L. and Janet Wade Docket No. 4703-94 Additions to Tax Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661 1982 $131,240 $65,620 * $32,810 1983 156,291 78,146 * 39,073 * 50 percent of interest due on portion of underpayment attributable to fraud. Stanley L. Wade Docket No. 4623-94 Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1984 $133,837 $33,459 $8,415 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After settlement of some issues, the issues for decision are: (1) Whether petitioners are liable for the fraud and other additions to tax, (2) whether petitioner may deduct $230,137 of claimed business expenses, and (3) whether the period of limitations bars assessment of the tax deficiencies and additions to tax for 1982, 1983, and 1984. FINDINGS OF FACT Some facts have been stipulated and are so found. When the petitions were filed, petitioners resided in Salt Lake City, Utah.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011