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Additions to Tax Penalties
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(3) 6653(a)(1)(A) 6661(a)6662(a)
1986 $110,582.82 --- $10,882 --- ---
1987 175,819.00 --- 8,791 --- ---
1988 80,136.00 $4,808.16 ---$4,007 ---
1989 121,302.00 --- --- --- $6,065
1991 0.00 --- --- --- ---
Respondent also asserted in the notice of transferee liability
that KBI owed, as additional amounts, the following:
Item Year Amount
Unpaid lien fees: 1986 $14.79
Interest refunded in error: 1987 1,502.90
Assessed interest:
1986 188,884.77
1987 120,203.59
1988 54,205.74
1989 45,832.50
1991 10,142.76
Accrued interest to March 15, 1995:
from Oct. 5, 1993 1986 51,229.73
from Oct. 5, 1993 1987 36,467.28
from Oct. 5, 1993 1988 5,472.83
from Oct. 5, 1993 1989 25,206.89
from Feb. 7, 1995 1991 92.95
Accrued addition to tax for failure to pay:
1986 12,096.91
1987 15,823.71
1988 12,884.12
1989 10,917.18
1991 92.95
KBI's total tax liability was $1,113,471.58; however, the unpaid
balance was $943,187.03. The issue for decision is whether
petitioner is liable as a transferee under section 69011 for (1)
1 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.
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Last modified: May 25, 2011