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Fraud Penalty
The third issue for decision is whether petitioners
are liable for the fraud penalty under section 6663(a) for
each of the years in issue. Respondent determined that
petitioner Crabtree Investments fraudulently omitted income
from its 1992, 1993, and 1994 returns on which there are
underpayments of $245,051, $103,218, and $118,840,
respectively. Accordingly, respondent determined that
Crabtree Investments is liable for civil fraud penalties
under section 6663 of $183,788, $77,414, and $89,130.
Respondent determined that petitioner Jerry Crabtree
fraudulently omitted income from her 1992, 1993, and 1994
returns on which there are underpayments of $97,728,
$49,310, and $76,554, respectively. Accordingly,
respondent determined that Ms. Jerry Crabtree is liable
for civil fraud penalties under section 6663 of $73,296,
$36,983, and $57,416.
Respondent further determined that petitioner Eddie
Crabtree fraudulently omitted income from his 1992, 1993,
and 1994 returns on which there are underpayments of
$99,346, $50,523, and $95,103, respectively. Accordingly,
respondent determined that Mr. Eddie Crabtree is liable for
civil fraud penalties under section 6663 of $74,510,
$37,892, and $71,327.
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