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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.
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