- 2 - Additions to Tax Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661 1983 $148,421 $74,211 50% of the $37,105 interest due on $148,421 1985 105,160 52,580 50% of the interest due on $105,160 26,290 All section references are to the Internal Revenue Code as in effect during the years in issue. After concessions, the issues for decision are: (1) Whether Mr. London's deposition in a prior proceeding is admissible in evidence on the ground that he is unavailable as a witness within the meaning of rule 804(a) of the Federal Rules of Evidence due to his refusal to answer any of the questions put to him on Fifth Amendment grounds; (2) whether the tapes and transcripts from the electronic surveillance conducted at Mr. London's business and the evidence derived therefrom are admissible in evidence; (3) whether petitioners failed to report income in 1983 and 1985, as determined by respondent using the net worth method of reconstructing income; (4) whether petitioners are liable for additions to tax for fraud under section 6653(b)(1) and (2) for 1983 and 1985; (5) whether petitioners are liable for additions to tax for substantial understatement of liability under section 6661(a) for 1983 and 1985; (6) whether Mrs. London intended to file a jointPage: 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