- 2 - Additions to Tax Year Deficiency Sec. 6653(b) Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661 1976 $263,353.75 $131,676.88 -- -- -- 1984 20,255.00 -- $10,113 1 $5,056 1985 244,848.00 -- -- -- -- 1987 24,986.00 -- -- -- -- 1 50 percent of the interest on $20,255. Respondent also determined that increased interest pursuant to section 6621(d) applied to the 1976 deficiency. By three amendments to answer for the year 1985, respondent (1) increased the deficiency by $367,776 (resulting in a total deficiency of $612,624), (2) asserted additions to tax pursuant to (a) section 6653(b)(1) in the amount of 50 percent of the underpayment, (b) section 6653(b)(2) in the amount of 50 percent of the interest payable with respect to the deficiency attributable to fraud, and (c) section 6659 in the amount of $94,950, and (3) asserted increased interest pursuant to section 6621(d). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the primary issues for decision are as follows: (1) Whether petitioner is liable for additions to tax for fraud for 1976, 1984, and 1985;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011