Henry F. K. Kersting - Page 3




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               3.  Whether section 162 allows petitioner to claim                     
          deductions for 1982 through 1988 for expenses incurred by                   
          petitioner's alter ego corporations.  We hold it does not.                  
               4.  Whether petitioner is liable for additions to tax for              
          failure to file under section 6651(a)(1) for 1982 through 1988.             
          We hold he is.                                                              
               5.  Whether petitioner is liable for additions to tax for              
          negligence under section 6653(a)(1) and (2) for 1982 through                
          1985, section 6653(a)(1)(A) and (B) for 1986 and 1987, and                  
          section 6653(a) for 1988.  We hold he is.                                   
               6.  Whether petitioner is liable for additions to his 1982             
          through 1988 taxes under section 6654(a) for failure to pay                 
          estimated taxes.  We hold he is.                                            
               Unless otherwise stated, section references are to the                 
          Internal Revenue Code in effect for the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded to the nearest dollar.                           
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and exhibits submitted therewith are                   
          incorporated herein by this reference.  Petitioner resided in               
          Honolulu, Hawaii, when he petitioned the Court.                             








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