T.C. Memo. 1998-207
UNITED STATES TAX COURT
GAYLON L. HARRELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7339-95. Filed June 15, 1998.
P did not file a Federal income tax return for 1991,
1992, or 1993. R determined deficiencies and additions to
tax for each year. R filed a motion under Rule 40, Tax
Court Rules of Practice and Procedure. This Court granted
R’s motion, in part, with respect to the deficiencies in
income tax and additions to tax under secs. 6651(a)(1) and
6654, I.R.C., but denied the motion as to the issue of P’s
liability for the fraud addition to tax under sec. 6651(f),
I.R.C. 1986, for 1993.
1. Held: P is liable for an addition to tax for fraud
under sec. 6651(f), I.R.C. 1986, for 1993.
2. Held, further, P is liable for a penalty of $10,000
under sec. 6673, I.R.C. 1986.
Gaylon L. Harrell, pro se.
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