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Addition to Tax Penalties
Year Deficiency Sec. 6653(b)(1)1 Sec. 6663(a)
1988 $107,589 $83,609 ---
1989 70,297 --- $52,723
1990 147,326 --- 110,495
1991 77,606 --- 58,205
1992 13,927 --- 10,445
1In the notice of deficiency, respondent also determined an addition to
tax for 1988 based on 50 percent of the interest due on the underpayment.
However, that addition to tax was improperly determined since the Technical
and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, sec. 1015(b)(2)(B),
102 Stat. 3568-3569, eliminated that addition to tax.
After concessions,1 the issues for decision are: (1) Whether
petitioners underreported their income for each year in issue;
(2) whether any part of an underpayment for each year in issue is
due to fraud; and (3) whether assessment of the alleged
deficiencies is barred by the statute of limitations.
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. Throughout this opinion, all amounts have been
rounded to the nearest dollar.
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. The petitioners, Robert
G. Bacon (Mr. Bacon), and Barbara Bacon (Mrs. Bacon), are husband
1Respondent has conceded the deficiency for the year 1992.
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