- 2 - 1 50 percent of the interest due on $2,294,259. By an amendment to answer, respondent asserts as his primary position an increase in the determination of deficiency for 1988 and additions to tax for fraud as follows: Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6653(b)(1)(A) 6653(b)(1)6653(b)(1)(B) 6654 1987 $2,294,259 $1,720,694 --1 $123,913 1988 110,500 -- $82,875 -- 6,573 1 50 percent of the interest due on $2,294,259. All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. All dollar amounts are rounded to the nearest dollar, unless otherwise indicated. The issues for decision are: (1) Whether petitioner had unreported income of $5,948,020 and $367,360 in 1987 and 1988, respectively. We hold he did. (2) Whether petitioner is liable for additions to tax for fraud for 1987 and 1988, or, in the alternative, whether petitioner is liable for the additions to tax for failure to file tax returns for 1987 and 1988, and for negligence. We hold petitioner is liable for the additions to tax for fraud for 1987 and 1988. (3) Whether petitioner is liable for self-employment tax of $5,387 and $5,859 in 1987 and 1988, respectively. We hold he is. (4) Whether petitioner is liable for the additions to tax pursuant to section 6654 for failure to pay estimated income tax. We hold he is.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