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Penalty and Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6661(a) Sec. 6662(a)
1986 $14,882 $2,853 $2,442 --
1987 13,971 2,811 2,811 --
1988 3,527 882 -- --
1989 3,825 956 -- --
1990 10,182 2,546 -- $2,036
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect for the years in issue,
and all Rule references are to the Tax Court Rules of
Practice and Procedure.
The parties have stipulated some of the facts.
The stipulation of facts filed by the parties and the
accompanying exhibits are incorporated herein by this
reference. Petitioners resided in the Commonwealth of
Pennsylvania at the time they filed the instant petition.
Petitioners did not file income tax returns for the
years in issue, 1986 through 1990, until 1992. At the time
of trial, petitioners had not filed returns for the years
1993 through and including 1996.
Respondent concedes that petitioners are not liable
for a small portion of the above deficiencies determined in
the notice of deficiency for 1989 and 1990. The issue for
decision is whether petitioners are liable for the subject
tax deficiencies, penalty, and additions to tax, other than
the portion of the deficiencies for 1989 and 1990 conceded
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Last modified: May 25, 2011