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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.
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