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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6654
1984 $ 43,110 $21,555 * $ 2,710
1985 10,601 5,301 * 607
Sec. Sec.
6653(b)(1)(A) 6653(b)(1)(B)
1986 134,065 $100,549 * 6,487
1987 1,180,713 885,535 * 63,770
Sec.
6653(b)(1)
1988 62,861 $47,146 -- 4,023
Sec.
6651(f)
1989 56,139 $41,561 -- 3,744
* 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.
After settlement of some issues, the issues for decision
are: (1) Whether petitioner received unreported income;
(2) whether petitioner is entitled to certain claimed deductions;
and (3) whether petitioner is liable for the fraud and other
additions to tax.
For the years in issue, petitioner has not filed Federal
income tax returns. Because petitioner did not maintain adequate
books and records, respondent determined petitioner’s income
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