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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined deficiencies, additions
to tax, and penalties for 1987, 1988, 1989, and 1990 with respect
to petitioner's Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1) Sec. 6653(b)(1)(B) Sec. 6654(a) Sec. 6651(f)
1987 $100,446 $75,335 $68,257 $5,392
1988 380,065 $285,049 24,447
1989 260,661 17,628 $195,496
1990 1,338,617 87,642 1,003,963
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure. All dollar amounts are rounded to the nearest dollar.
The parties have agreed that the proper amounts of
petitioner's income tax deficiencies are $31,554, $226,297,
$42,521, and $835,656 for the 1987, 1988, 1989, and 1990 taxable
years, respectively. The parties have further agreed that
petitioner is liable for the addition to tax under section
6654(a) for the 1987, 1988, 1989, and 1990 taxable years.
After these concessions by both parties, the sole issue for
decision is whether petitioner is liable for the additions to tax
for fraud under section 6653(b)(1)(A) and (B) for the 1987
taxable year and section 6653(b)(1) for the 1988 taxable year and
the additions to tax for fraudulent failure to file timely income
tax returns under section 6651(f) for the taxable years 1989 and
1990. In the event we should determine that petitioner is not
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