- 3 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011