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Betty June Dykstra:
Penalties Additions to Tax
Year Deficiency Sec. 6663 Sec. 6662(a) Sec. 6651(a)(1) Sec. 6651(f) Sec. 6654
1994 * $5,355 $808 $2,865 $0 $0
1995 33,110 0 0 0 24,372 1,704
* Respondent determined a deficiency of $11,684 against both Betty June and Pieter
Dykstra.
Pieter Dykstra:
Penalty Additions to Tax
Year Deficiency Sec. 6662(a) Sec. 6651(a)(1) Sec. 6654
1994 * $808 $2,865 $0
1995 25,621 0 6,311 1,242
* Respondent determined a deficiency of $11,684 against both
Betty June and Pieter Dykstra.
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 issues for our decision are: (1)
Whether petitioners had unreported income from Conoco, Inc.
(Conoco), during 1994 and 1995; (2) whether petitioners were
entitled to their claimed itemized deductions of $17,872 in 1994;
(3) whether petitioner Betty June Dykstra (Mrs. Dykstra) is
liable for the fraud penalty pursuant to section 6663(b) for 1994
and an addition to tax for fraudulently failing to file a Federal
income tax return pursuant to section 6651(f) for 1995; (4)
whether petitioners are liable for the accuracy-related penalty
for negligence pursuant to section 6662(a) for 1994; (5) whether
petitioners are liable for an addition to tax pursuant to section
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Last modified: May 25, 2011