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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;
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Last modified: May 25, 2011