Harold Pottorf - Page 2




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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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