Ella Freidus - Page 15

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          preparation of her tax returns for the earlier years and would               
          not resume work until fees in arrears had been satisfied and a               
          retainer of $10,000 was paid.  Payments totaling $80,236 were                
          made during 1989 and 1990 to Eisner & Lubin for professional                 
          services.  Eisner & Lubin performed an additional $40,000 worth              
          of services for which petitioner was billed.  Eisner & Lubin did             
          not prepare any requests for extension or tax returns for                    
          petitioner or any of the nominee corporations for any year                   
          subsequent to 1980.                                                          
               The sole issue for decision is whether petitioner is liable             
          for the additions to tax for fraud under sections 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              
          1989 and 1990 taxable years.                                                 
               Section 6653(b)(1)(A) and section 6653(b)(1), as in effect,             
          respectively, for the 1987 and 1988 returns in this case impose              
          an addition to tax equal to 75 percent of the portion of the                 
          underpayment which is attributable to fraud.  Section                        
          6653(b)(1)(B), as in effect for 1987, imposes a further addition             
          to tax equal to 50 percent of the interest payable under section             
          6601 with respect to the portion of the underpayment attributable            
          to fraud.  If any portion of the underpayment is attributable to             

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