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Addition to Tax
Year Deficiency Sec. 6651(a)1 Sec. 6654(a)
1988 $12,909 $2,802 $705
1989 53,816 13,404 3,623
1990 9,928 2,482 655
1991 58,170 14,543 3,347
1992 10,137 2,534 440
1993 17,712 4,428 742
After concessions by both parties, we must decide the
following issues:
(1) Whether the notices of deficiency in this case were
valid, granting us jurisdiction. We hold that the notices were
valid and that we have jurisdiction.
(2) Whether the notices of deficiency were arbitrary and
erroneous, which would cause them to lose their presumption of
correctness. With the exception of $35,873 of unreported income
determined in the notice for 1993, we hold that the notices were
not arbitrary and erroneous and that they are entitled to the
presumption of correctness.
(3) Whether petitioner is liable for the deficiencies in tax
as determined by respondent. We hold that petitioner is liable
to the extent discussed below.
(4) Whether petitioner is liable for the additions to tax as
determined by respondent. We hold that petitioner is liable to
the extent discussed below.
1 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.
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Last modified: May 25, 2011