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pursuant to section 6653(b) for the years 1978 through 1983 and
1985 through 1988, and the fraud penalty pursuant to section 6663
for 1989.2 We hold he is. (8) Whether petitioner is liable for
additions to tax for underpayment of individual estimated tax
pursuant to section 6654 for the years 1978 through 1983 and 1987
through 1989. We hold we lack jurisdiction for the years 1978
through 1983; however, he is for the years 1987 through 1989.
(9) Whether petitioner is liable for additions to tax for
substantial understatement pursuant to section 6661 for the years
1982, 1983, 1985, and 1986. We hold he is. (10) Whether
petitioner is liable for an addition to tax for failure to file a
timely return pursuant to section 6651(a)(1) for 1992. We hold
he is.
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. Petitioner resided in
Florida at the time he filed the petitions in these consolidated
cases.
2Petitioner did not file a return for 1989. Accordingly,
the fraud penalty should be under sec. 6651(f) for fraudulent
failure to file, not under sec. 6663. The latter section applies
only where a return is filed. See sec. 6664(b). This is an
error in form only and does not have a substantive effect on
these cases. Cf. Pietz v. Commissioner, 59 T.C. 207, 213-214
(1972).
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