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Respondent also determined in the alternative that petitioners
are liable for additions to their 1988 through 1990 taxes under
sections 6651(a)(1) and 6654.
Respondent conceded in the answer that petitioners are not
liable for the addition to tax under section 6661 or the
penalties under section 6662. Following this concession, and a
ruling by the Court as to 1990, the only issues left to decide
are:
1. Whether the period of limitations for assessment of tax
for 1988 and 1989 expired before respondent issued the notice of
deficiency to petitioners. We hold it did not.
2. Whether petitioners are liable for the deficiency
determined by respondent in petitioners' 1989 income tax due to
unreported income. We hold they are.
3. Whether petitioners are liable for the addition to tax
for fraud under section 6653(b)(1) for 1988 and the addition to
tax for fraudulent failure to file under section 6651(f) for
1989. We hold they are not.
4. Whether petitioners are liable for additions to tax for
failing to timely file their 1988 and 1989 returns under section
6651(a). We hold they are.
5. Whether petitioners are liable for additions to tax for
failing to pay estimated taxes under section 6654 for 1988 and
1989. We hold they are.
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