- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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