- 42 - Year 1984 1985 1986 1987 1988 Net amount per CD Sch. $1,575,000 $1,161,163 $1,752,537 $1,708,500 $1,525,300 Less: Invoices dated after 8/88 -0- -0- -0- -0- 155,300 Interest paid to CD participants 304,864 282,452 406,917 484,548 -0- Lesser of W-2 wages or FIP's NOL 251,665 233,033 532,201 395,810 122,067 Unreported income 1,018,471 645,678 813,419 828,142 1,247,933 For each of the years 1984 through 1987, the unreported income exceeds 25 percent of the income reported on the return. Accordingly, we conclude that for each of those years the statute of limitations does not bar the assessment of the deficiency or additions to tax. Addition to Tax for Negligence Respondent determined that petitioners are subject to an addition to tax for negligence under section 6653 for the years in issue. Section 6653(a)(1) (for 1984, 1985, and 1988) or section 6653(a)(1)(A) (for 1986 and 1987) imposes an addition to tax equal to 5 percent of the underpayment if any part of the deficiency was due to negligence or intentional disregard of rules or regulations. Section 6653(a)(2) (for 1984 and 1985) or section 6653(a)(1)(B) (for 1986 and 1987) provides for an addition to tax in the amount of 50 percent of the interestPage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
Last modified: May 25, 2011