Carlye A. Christianson - Page 2




                                        - 2 -                                         
                            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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