- 582 - the assessment and collection of their Federal income taxes for such years are not barred by the statute of limitations. See sec. 6501(c)(2). Issue 33. The Liabilities of Kanter, Ballard, and Lisle for Additions to Tax for Negligence OPINION The Court has held that Kanter is liable for fraud additions to tax for the years 1978 through 1984 and for the years 1986 through 1989. The Court has also held that Ballard is liable for the fraud addition to tax for the years 1975 through 1982, for the year 1984, and for the years 1987 through 1989. The Court has further held that Lisle is liable for the fraud addition to tax for the year 1984 and the years 1987 through 1989. In the notices of deficiency and/or in amended pleadings, respondent also determined and/or asserted the additions to tax for negligence or intentional disregard of rules or regulations against Kanter under section 6653(a) with respect to activities other than the Prudential activities as to which the Court has concluded that the fraud addition to tax is applicable.63 Respondent agrees on brief that for years prior to 1986, if the addition to tax for fraud is applicable, the amount of the fraud addition to tax is calculated on the entire underpayment of tax, including underpayments relating to nonfraudulent 63 See supra note 3 outlining the various versions of section 6653(a) in effect during the years at issue.Page: Previous 572 573 574 575 576 577 578 579 580 581 582 583 584 585 586 587 588 589 590 591 Next
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