John Boyd Tenney - Page 17

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          Fraud and Other Additions to Tax                                            
               For 1984 and 1985, if any portion of a tax underpayment is             
          attributable to fraud, the addition to tax for fraud under                  
          section 6653(b)(1) equals 50 percent of the total underpayment of           
          tax, and increased interest under section 6653(b)(2) equals 50              
          percent of interest payable under section 6601 but only with                
          respect to that portion of the underpayment that is attributable            
          to fraud.  Respondent has the burden of proving what portion of             
          the underpayment is attributable to fraud.                                  
               For 1986, 1987, and 1988, the addition to tax for fraud                
          under section 6653(b)(1) equals 75 percent of that portion of a             
          tax underpayment that is attributable to fraud, and for 1986 and            
          1987, increased interest under section 6653(b)(1)(B) equals 50              
          percent of interest payable under section 6601 with respect to              
          that portion of a tax underpayment that is attributable to fraud.           
               For 1986, 1987, and 1988, where respondent proves that any             
          part of a taxpayer's underpayment of income tax is due to fraud,            
          fraud is presumed with respect to the entire underpayment unless            
          the taxpayer proves otherwise by a preponderance of the evidence.           
          Sec. 6653(b)(2).                                                            
               For 1989, if a taxpayer fraudulently fails to file a tax               
          return, the fraudulent failure to file addition to tax under                
          section 6651(f) provides for an addition to tax equal to                    
          15 percent of the amount required to be shown as tax on the                 





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