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Additions to Tax
Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661(a)
$1,581,128 $790,564 1 $395,282
1Plus 50 percent of the interest payable under sec.
6601 with respect to the portion of the underpayment which
is attributable to fraud.
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect for 1983.
After concessions, the issues remaining for decision
are: (1) Whether, and to what extent, petitioner realized
unreported income in 1983 from the sale of marijuana; (2)
whether petitioner is liable for self-employment tax on
the income earned from the sale of marijuana; (3) whether
petitioner is entitled to deduct expenses allegedly
incurred during 1983 for legal services; (4) whether
petitioner is liable for the additions to tax for fraud
prescribed by section 6653(b)(1) and (2); (5) whether
petitioner is liable for the addition to tax for
substantial understatement of liability prescribed by
section 6661(a); and (6) whether the period of limitations
on assessment and collection of tax prescribed by section
6501 expired before respondent issued the subject notice
of deficiency.
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Last modified: May 25, 2011