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Gerald A. Sadler, pro se.
Derek B. Matta and Gordon P. Sanz, for respondent.
VASQUEZ, Judge: Respondent determined the following
deficiency in and penalties on petitioner's Federal income tax:
Penalties
Year Deficiency Sec. 6663
1989 $19,797.59 $44,473.19
1990 -- 19,500.00
By amendment to answer, respondent increased the amount of
the fraud penalty for 1989 to $55,947.37.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. After concessions,1 the issues for decision are (1)
whether petitioner is liable for the fraud penalty for 1989 and
1990, and (2) whether the periods of limitation for 1989 and 1990
have expired.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition, Gerald A. Sadler (Mr. Sadler) resided in Houston,
Texas.
1 Respondent concedes that there is no deficiency for 1989.
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