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Respondent determined deficiencies and additions to tax as
follows:
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654
1993 $37,428 $6,397 $1,017
1994 41,918 8,829 1,782
Petitioner petitioned the Court on December 30, 1996, to
redetermine respondent's determination of these deficiencies and
additions to tax.
We must decide: (1) Whether petitioner is liable for the
deficiencies determined by respondent; (2) whether petitioner is
liable for the additions to tax determined by respondent under
section 6651(a)(1); (3) whether petitioner is liable for the
additions to tax determined by respondent under section 6654; and
(4) whether petitioner is liable for a penalty under section
6673. We hold for respondent on all issues. We also hold that
petitioner is liable for a penalty under section 6673 and require
him to pay to the United States a penalty of $5,000. Unless
otherwise stated, section references are to the Internal Revenue
Code in effect for the years in issue, and Rule references are to
the Tax Court Rules of Practice and Procedure. Dollar amounts
are rounded to the nearest dollar.
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Last modified: May 25, 2011