- 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