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Year Deficiency Fraud Penalty Sec. 6663
1992 $97,728 $73,296
1993 49,310 36,983
1994 76,554 57,416
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect during the years in
issue.
Respondent determined the following deficiencies in
and penalties with respect to the Federal income tax of
petitioner Eddie L. Crabtree:
Year Deficiency Fraud Penalty Sec. 6663
1992 $99,346 $74,510
1993 50,523 37,892
1994 95,103 71,327
Respondent also determined the following deficiencies
in and penalties with respect to the Federal income tax of
petitioner Crabtree Investments, Inc. (Crabtree Invest-
ments):
Year Deficiency Fraud Penalty Sec. 6663
1992 $245,051 $183,788
1993 103,218 77,414
1994 118,840 89,130
Each petitioner filed a timely petition for
redetermination in this Court, and their cases were
consolidated for trial, briefing, and opinion by order of
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