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failed to appear in person or through counsel. Respondent filed
a motion asking this Court to find petitioner in default and
enter a decision against him. By order dated November 5, 1996,
this Court granted respondent's motion in part and held
petitioner liable for the underlying deficiency and the section
6654(a) addition to tax. This Court denied respondent's motion
with respect to the section 6653(b) additions to tax and restored
the case to the general docket for trial.
This case was subsequently called from the calendar of this
Court's April 28, 1997, trial session in Boston, Massachusetts.
Petitioner failed to appear in person or through counsel, and
respondent rested on the facts previously established pursuant to
Rules 91(f) and 90(c).
Respondent, on brief, conceded that petitioner is not liable
for the section 6653(b) addition to tax relating to petitioner's
1979 tax year. As a result, the issues we must decide are as
follows:
1. Whether petitioner, pursuant to section 6653(b), is
liable for an addition to tax for fraud relating to his 1980 tax
year. We hold that he is liable.
2. Whether petitioner, pursuant to section 6651(a), is
liable for an addition to tax for failing to file his 1979
Federal income tax return in a timely manner. We hold that he is
liable.
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