Robert E. Iles and Monica M. Iles - Page 2

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                    2.  Held, further, H is liable for additions to tax for           
               civil fraud for 1980, 1981, and 1982.  Secs. 6653(b) and               
               6653(b)(1), I.R.C. 1954.                                               
                    3.  Held, further, H is liable for additional additions           
               to tax for 1982 based on the portion of the deficiency                 
               attributable to fraud; amounts redetermined.  Sec.                     
               6653(b)(2), I.R.C. 1954.                                               
               Robert E. Iles and Monica M. Iles, pro sese.                           
               James D. Hill and Matthew J. Fritz, for respondent.                    

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               CHABOT, Judge:  Respondent determined deficiencies in                  
          Federal individual income tax and additions to tax under sections           
          6653(b)1 (fraud), 6654 (failure to pay estimated tax), and 6661             
          (substantial understatement of income tax) against petitioner               
          Robert E. Iles2 as follows (amounts rounded to nearest dollar):             
                           Additions to Tax                                           
                                Sec. 6653  Sec. 6653                                  
       Year Deficiency Sec. 6653(b)    (b)(1)    (b)(2)     Sec. 6654    Sec. 6661    
       1980  $103,197     $54,369    -           -        $6,221        -             
       1981    253,014     126,507         -            -        19,387        -      
       1982   605,062 -         $302,531        1   58,908     $151,266               

            1  50 percent of the interest due on the entire deficiency.               

               1    The substance of sec. 6653(b) as in effect for 1980 and           
          1981, and sec. 6653(b)(1) as in effect for 1982, appears in secs.           
          6651(f) and 6663 of present law.                                            
               Unless indicated otherwise, all section references are to              
          sections of the Internal Revenue Code of 1954 as in effect for              
          the years in issue, and all Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            
               2    On Sept. 15, 1987, respondent issued a joint notice of            
          deficiency to petitioners for 1980, and, in the absence of                  
          previously filed tax returns for 1981 and 1982, separate notices            
          of deficiency to each petitioner for 1981 and 1982.                         



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