Janet N. Drummond - Page 2




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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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