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Additions to Tax
Sec. Sec. Sec. Sec. Sec.
6653 6653 6653 6653 6661
Year Deficiency (b)(1) (b)(1)(A) (b)(1)(B) (b)(2)(a)
1984 $814 $2,745 -- -- 50% of the $1,372
interest due
on $5,211
1985 816 5,888 -- -- 50% of the 2,944
interest due
on $11,215
1986 757 -- $9,662 50% of the -- 3,221
interest due
on $12,865
1987 2,145 -- 6,779 50% of the -- 2,260
interest due
on $8,997
Respondent determined the additions to tax for fraud only against
petitioner Roy G. Welker (Mr. Welker).
After concessions, the issues for decision are: (1) Whether
Mr. Welker is liable for additions to tax for fraud for 1984,
1985, 1986, and 1987; and (2) whether petitioners are liable for
additions to tax for a substantial understatement for 1984, 1985,
1986, and 1987. Unless otherwise noted, 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.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners, husband and wife, resided
in Belleville, Illinois, at the time they filed their petition.
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