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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.
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