- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011