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(fraud), 6661 (substantial understatement of tax liability), and
6663 (fraud) against petitioners as follows:
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6661 Sec. 6663
1988 $9,090 $6,818 $2,273
1989 20,791 $15,593
1990 31,436 23,577
Petitioners Anthony and Gloria Donnora, hereinafter
sometimes referred to as Anthony and Gloria, respectively,
invoked this Court’s jurisdiction by filing a timely petition
from the notice of deficiency, disputing the entire amounts of
the deficiencies and additions to tax.
2. Answer
Respondent filed an answer to the petition, including
specific allegations with regard to the fraud determinations. In
paragraph 7 of the answer respondent alleges among other things
that both Anthony and Gloria (1) failed to deposit substantial
amounts of the cash receipts of Forkston Fireworks Mfg. Co.,
Inc., hereinafter sometimes referred to as Forkston, into
Forkston’s bank account, (2) used the undeposited cash receipts
for personal expenses, and (3) failed to inform their accountant
of the undeposited Forkston cash receipts. Further, in paragraph
7 respondent alleges that petitioners’ extensive use of cash and
2(...continued)
to sections of the Internal Revenue Code of 1986 as in effect for
the years in issue.
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