- 2 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011