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Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year 6651(f) 6653(b)(1) 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(2)
1985 -- $3,552 -- -- *
1986 -- -- $11,981 ** --
1987 -- -- 9,218 *** --
1988 -- 12,427 -- -- --
1989 $12,983 -- -- -- --
1990 29,429 -- -- -- --
* 50 percent of the interest due on $7,103.
** 50 percent of the interest due on $15,975.
*** 50 percent of the interest due on $5,791.
The issues for decision are:
(1) Have the respective periods of limitations prescribed by
section 65011 for the years at issue expired? We hold that they
have not.
(2) Is petitioner liable for the additions to tax under
section 6653(b) for each of the years 1985, 1986, and 1987 and
under section 6651(f) for each of the years 1989 and 1990? We
hold that she is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.2
Petitioner resided in San Diego, California, at the time the
petition was filed.
Petitioner, an attorney, was a sole practitioner and aspired
to emulate the amount of money made by similarly situated at-
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2Unless otherwise indicated, our Findings of Fact and Opin-
ion pertain to the years at issue.
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Last modified: May 25, 2011