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Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2)
1983 $52,450 $26,225 1
1984 27,852 13,926 1
1985 12,376 6,188 1
Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B)
1986 $39,035 $29,276 1
1987 18,827 14,120 1
150 percent of the interest due on the entire deficiency.
Due to concessions1 by respondent, the following amounts
represent respondent’s reduced determinations:
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2)
1983 $50,450 $25,225.00 1
1984 25,892 12,946.00 1
1985 10,749 5,374.50 1
Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B)
1986 $36,917 $27,687 1
1987 16,063 12,047 1
150 percent of the interest due on the entire deficiency.
Due to petitioner’s failure to communicate with respondent
or to appear at the Court’s Kansas City, Missouri, February 22,
1999, trial session, respondent moved to dismiss this case for
lack of prosecution and for a default judgment. Because
1 Respondent’s motion, in the portion containing the
concessions, referenced I.R.C. sec. 6653(a) (negligence) rather
than I.R.C. sec. 6653(b) (fraud) for the 1986 and 1987 tax years.
The addition to tax amounts set forth in the motion reflect that
respondent did not concede the fraud penalty in lieu of the
negligence penalty for the 1986 and 1987 tax years. The amounts
and section numbers set forth in the notice of deficiency for
1986 and 1987 also reflect that the fraud penalty was determined
and intended.
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Last modified: May 25, 2011