- 2 - Additions to Tax and Penalties Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6653(b)(1) Sec. 6663 1986 $25,086 $18,815 * --- --- 1987 20,122 15,092 * --- --- 1988 26,970 --- --- $20,228 --- 1989 44,426 --- --- --- $33,320 1990 62,817 --- --- --- 47,113 1991 38,498 --- --- --- 28,874 * Amounts to be calculated at 50 percent of interest due on portion of underpayments attributable to fraud. 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 embezzled funds that should be charged as gross income to petitioner and whether the fraud additions to tax and fraud-related penalties apply. FINDINGS OF FACT Some of the facts have been stipulated and are so found. When the petition was filed, petitioner resided in South Jordan, Utah. From 1984 until terminated in 1991, petitioner was employed as a pharmacist at the outpatient pharmacy (OPP) at LDS Hospital in Salt Lake City, Utah. The procedures for the “closing” each day of the cash register by the OPP pharmacists consisted of the following steps:Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011