- 2 - Excise Taxes Addition to Tax Year Sec. 4975(a) Sec. 4975(b) Sec. 6651(a)(1) 1988 $409 -- $102 1989 901 -- 225 1990 1,897 -- 474 1991 3,160 -- 790 1992 4,809 -- 1,202 1993 6,660 -- 1,665 1994 8,737 -- 1,311 19981 -- $174,761 -- 1 For the taxable period ending January 15, 1998. 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. After concessions, the issue is whether respondent is precluded from assessing the deficiencies and additions. Background The parties submitted this case fully stipulated pursuant to Rule 122. When the petition was filed, petitioner resided in Akron, Ohio. During 1988 and 1990, petitioner was married. During 1988 through 1990, petitioner was president, director, and majority stockholder (i.e., owner of at least 51 percent of the stock) of Cotter Merchandise Storage Co. (the company). The company maintained the Cotter Merchandise Storage Co. Defined Benefit Pension Plan (the plan), which met the requirements of section 401. Petitioner was a trustee and participant of the plan.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011