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Bobby E. Welch, docket No. 23725-95
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6653(a)(1) Sec. 6653(a)(1)(A) Sec. 6661(a)
1986 $173,118 $43,517 --- $8,703 $10,107
1987 27,070 6,860 --- 1,372 5,722
1988 25,958 6,564$1,313 --- 4,952
All section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
Pursuant to section 6653(a)(1)(B) respondent also determined
additions to tax for 1986 and 1987 in amounts equal to 50 percent
of the interest due on the respective deficiencies.
Bobby E. Welch & Kathleen Newman, docket No. 24065-95
Additions to Tax Penalties
Year Deficiency Sec. 6651(a) Sec. 6662(a)
1989 $49,091 $12,327 $9,818
1990 74,461 18,634 14,892
The deficiencies result from increases in gross income based
on bank deposit analyses and the disallowances of net operating
loss carryovers. The primary issues concern those adjustments
and whether petitioners are liable for the additions to tax and
penalties for the years at issue. Respondent has made some
concessions that will be reflected in the Rule 155 computations.
Summary of Background Facts
Certain facts have been stipulated and are so found. The
stipulation of facts with attached exhibits is incorporated
herein by this reference.
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