- 2 -
1985 32,156 -0- 7,235 8,039
1986 33,288 -0- 7,490 8,322
1987 34,355 -0- 7,730 8,589
1988 35,374 -0- 7,959 8,844
1989 35,374 -0- 7,959 8,844
1990 35,374 -0- 7,959 6,721
1991 35,374 -0- 7,959 4,599
1992 35,374 -0- 7,959 2,476
1993 21,624 $707,488 65,620 7,291
After concessions, the issues for decision are:
1. Whether petitioners are disqualified persons as
described in section 4975(e)(2). We hold that they are, and that
they are jointly and severally liable for the 5-percent excise
tax on prohibited transactions under section 4975(a) for 1982 to
1993.
2. Whether petitioners are liable for additions to tax
under section 6651(a)(1) for 1982 to 1993. We hold that they are
to the extent discussed below.
At trial, respondent conceded that petitioners are not
liable for the 100-percent excise tax under section 4975(b) for
1993 or the additions to tax under section 6651(a)(2) for 1982 to
1993. Respondent also conceded that the addition to tax under
section 6651(a)(1) for 1993 does not exceed $7,959.
References to petitioner are to Edward Clasby. References
to the Garrahan Agency are to the C.T. Garrahan Insurance Agency,
Inc. 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.
I. FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
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