- 2 - Additions to Tax Penalty Sec. Sec. Sec. Sec. Sec. Year Deficiency 6653(b) 6653(b)(1)(A) 6653(b)(1)(B) 6661 6663 1987 $32,177 - $24,133 1 $8,044 - 1988 26,326 $19,745 - - 6,582 - 1989 27,199 - - - - $20,399 1990 11,624 - - - - 8,718 150 percent of the interest due on the deficiency. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues to be decided are as follows: (1) Whether the assessment and collection of taxes, additions to tax, and penalties for 1987, 1988, and 1990 are barred by the period of limitations pursuant to section 6501(a) or are allowed under either (a) the fraud exception to the general period of limitations provided in section 6501(c)(1) or (b) the extended 6-year period of limitations provided in section 6501(e)(1)(A); and (2) if assessment and collection are not barred for 1987, 1988, and 1990, then, for each of those years and for 1989 we must decide whether: (a) and, if so, to what extent, petitioner omitted 1(...continued) increased deficiencies, the issues relating to such increased deficiencies appear to have been tried by consent. Rule 41(b)(1). We, however, do not address the increased deficiencies because the decision we reach below results in deficiencies less than those determined by respondent in the notice of deficiency.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011