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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1)1 6653(b)(2) 6654
1983 $19,113 $9,607 * --
1984 9,025 4,513 * $509
* 50 percent of the interest due on the portion of the underpay-
ment attributable to fraud. Respondent determined that the
entire underpayment for each of the years 1983 and 1984 was due
to fraud.
Respondent determined the following deficiencies in, and
additions to, the tax of petitioner Daryl Drummond (Mr.
Drummond):
Additions to Tax
Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2)
1983 $34,726 $17,363 *
1984 21,038 10,519 *
* 50 percent of the interest due on the portion of the underpay-
ment attributable to fraud. Respondent determined that the
entire underpayment for each of the years 1983 and 1984 was due
to fraud.
The issues for decision are:
(1) Should the determinations in the notice of deficiency
(notice) issued to Ms. Drummond be sustained? We hold that they
should.
(2) Should the determinations in the notice issued to Mr.
Drummond be sustained? We hold that they should except to the
extent that respondent's concession on brief that Mr. Drummond's
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011