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Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec. Sec.
6653 6653 6653 6653 6653 6653 6653 Sec.
Year Deficiency (a)(1) (a)(1)(A) (a)(1)(B) (b)(1) (b)(1)(A) (b)(1)(B) (b)(2) 6661
1985 $163,048 -- -- -- $81,524 -- -- ** $40,762
1986 168,368 -- $ 336 * -- $121,229 ** -- 42,092
1987 154,962 -- 2,220 * -- 82,915 ** -- 38,741
1988 21,488 $39 -- -- 15,525 -- -- -- 5,372
* 50 percent of interest due on portion of
underpayment attributable to negligence.
** 50 percent of interest due on portion of
underpayment attributable to fraud.
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.
The primary issues for decision are whether petitioners are
to be charged with additional partnership income and whether
petitioners are liable for the fraud and other additions to tax.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife and resided in Hayward,
California, at the time they filed their petition in this case.
Hereinafter references to petitioner are to Martin Schachter.
In 1954, petitioner’s father Ben Schachter began operating
as a sole proprietorship a wholesale soap distribution business
under the name of Cal Ben Co. (Cal Ben).
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Last modified: May 25, 2011