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Additions to Tax and Penalties
Sec. Sec. Sec.
Year 6653(b)(1)(A) 6653(b)(1) 6663
1987 $7,324 -- --
1988 -- $8,127 --
1989 -- -- $13,576
After concessions by the parties, the issues remaining for
decision are whether this Court has jurisdiction over this case
and whether petitioner fraudulently underpaid his Federal income
tax for 1989. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
This case was submitted fully stipulated, and the facts set
forth in the stipulation are incorporated in our findings by this
reference. Jerry V. Rice (petitioner) resided in Albuquerque,
New Mexico, at the time the petition in this case was filed.
During 1989, petitioner was employed as a certified public
accountant (C.P.A.) with two companies, Jerry V. Rice C.P.A.,
P.C. (Jerry Rice, P.C.), and its successor, Rice and Associates
C.P.A., P.C. (Rice and Associates). Petitioner was the sole
shareholder in both companies and was responsible in each for
keeping records and paying payroll taxes. Accordingly,
petitioner knew that neither Jerry Rice, P.C., nor Rice and
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