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Year Deficiency Sec. 6663
1990 $11,998 $8,999
1991 11,803 8,852
1992 11,225 8,419
1993 15,769 11,827
The deficiency in income tax and penalty for 1993 have been
reduced to $15,453 and $11,590, respectively, to reflect
respondent's concession that the unreported income amount
determined for petitioner's 1993 tax year is $52,000, rather than
the $52,989 determined in the notice of deficiency. The issues
for our consideration are: (1) Whether petitioner is estopped,
by reason of a prior conviction for criminal tax evasion, from
denying that the $188,000 he received was taxable income during
the years in issue; (2) whether petitioner is estopped from
denying that the deficiencies asserted against him for the years
at issue were due to fraud with the intent to evade tax; and
(3) whether the assessment and collection of the deficiencies in
income tax and penalties for petitioner's taxable years 1990,
1991, and 1992 are barred by expiration of the statutory period
of limitations.
This case was submitted fully stipulated pursuant to Rule
122.1 At the time the petition in this case was filed,
petitioner, Mr. Richard Frey, resided in Milan, Michigan.
1 The stipulation of facts and the attached exhibits are
incorporated by this reference. All Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in issue, unless otherwise indicated.
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