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Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6651(f) Sec. 6654
1989 $18,328 -- $13,746 $1,240
1990 57,912 -- 43,434 3,792
1991 66,994 -- 50,246 3,829
1992 48,870 -- 36,653 2,132
1993 9,293 -- 3,206 389
1994 9,603 $2,401 -- 498
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise specified.
Following the concession by respondent of the section
6651(f) addition for 1993, the principal issues remaining for
decision are:
1. Whether petitioner is entitled to deductions, in excess
of the amounts allowed by respondent for each of the years 1989-
92, on account of business expenses paid with cash.
2. Whether petitioner's failure to file Federal income tax
returns for each of the years 1989-92 was "fraudulent" within the
meaning of section 6651(f).
3. Whether respondent's determinations of petitioner's
unreported income for 1993 and 1994 should be sustained.
4. Whether the section 6651(a) addition applies to
petitioner's failure to file a return for 1994.
5. Whether petitioner is liable for the section 6654
addition for failure to pay estimated tax for each of the years
1989-94.
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Last modified: May 25, 2011