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1990 1991 1992 1993
Gross
receipts $64,653.27 $129,270.11 $43,666.91 $52,712.22
Father's
bull (9,500.00) --- --- ---
Adjusted gross
income 55,153.27 129,270.11 43,666.91 52,712.22
Stipulated
deductions (28,723.00) (81,888.00) (31,304.00) (40,819.00)
Cash cattle
feed expenses (2,283.00) (1,970.10) (1,570.07) (1,624.90)
Barn
depreciation (3,000.00) (3,000.00) (3,000.00) (3,000.00)
Net income 21,147.27 42,412.01 7,792.84 7,268.32
Issue 3. Section 6651(f) Addition to Tax
The final issue is whether petitioner is liable for the
fraudulent failure to file addition to tax pursuant to section
6651(f) for each of the years in issue. Respondent contends that
petitioner is liable for the addition to tax. Petitioner
disagrees.
Section 6651(f) imposes an addition to tax for failure to file
a tax return. Where the failure to file is fraudulent, the
addition to tax is 15 percent of the amount required to be shown on
the return for each month beyond the return's due date, up to a
maximum of 75 percent. (If the failure to file is not fraudulent
and is not due to reasonable cause, the addition to tax is 5
percent of the amount required to be shown on the return for each
month that the return is not filed, up to a maximum of 25 percent.)
Respondent bears the burden of proving by clear and convincing
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