-2-
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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