- 2 - Fraud Penalty Year Deficiency Sec. 6663 1993 $192,142 $144,107 1994 185,261 138,946 1995 123,633 92,725 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. The issues for decision involve the amount of unreported income that should be charged to petitioners and petitioners’ liability under section 6663 for the fraud penalty. Hereinafter all references to petitioner are to Rebecca Adair. FINDINGS OF FACT Because petitioners failed to respond to respondent's requests for admission, factual matters set forth in respondent's requests for admission are deemed admitted. See Rule 90(c). When the petition was filed, petitioners resided in Clinton, Louisiana. Petitioners and Delwin Houser, Rebecca Adair’s step- father, operate a roofing business known as H & H Sheet Metal (the roofing business). The evidence does not establish how ownership of the roofing business is divided between petitioners and Delwin Houser.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011