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to section 6651 for 1991-95 with respect to asserted accumulated
funding deficiencies for the law offices of Neal A. Sanders' money
purchase pension and profit sharing plans (the first deficiency
notice), as follows:
Addition to Tax
Year Sec. 4971(a) Deficiency Sec. 4971(b) Deficiency Sec. 6651(a)
1991 $772 --- $193
1992 1,310 $12,604 327
1993 3,250 31,999 812
1994 3,042 53,624 ---
1995 5,362 53,624 804
The second notice determined Federal excise tax deficiencies
pursuant to section 4975 and additions to tax pursuant to section
6651 for 1992-95 (the second deficiency notice) with respect to an
asserted prohibited transaction (the borrowing of money) engaged in
by the law offices of Neal A. Sanders with both its money purchase
pension and profit sharing plans, as follows:
Addition to Tax
Year Sec. 4975(a) Deficiency Sec. 4975(b) Deficiency Sec. 6651(a)(1)
1992 $87 --- $22
1993 294 --- 74
1994 518 --- 130
1995 775 $17,087 116
The third notice determined Federal income tax deficiencies and
accuracy-related penalties pursuant to section 6662 for 1992 and
1993 (the third deficiency notice) with regard to Neal Alan and
Linda Sanders, husband and wife, as follows:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1992 $22,927 $4,585
1993 18,478 3,696
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