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Joseph J. House Inc., docket No. 8665-98
Year ended Addition to tax Accuracy-related penalty
June 30 Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1994 $39,723 $9,931 $7,945
By amendment to answer in docket No. 8664-98, respondent
affirmatively asserted that petitioner was liable for an
increased deficiency in tax and that petitioner was liable for
the fraud penalty.1 On brief, respondent conceded the deficiency
in tax, addition to tax, and accuracy-related penalty in docket
No. 8665-98. Following concessions of the parties, we decide the
following issues:
1. Whether petitioner had unreported income for 1994
related to his accounting business. We hold he did to the extent
set forth herein.
2. Whether petitioner is liable for the fraud penalty. We
hold he is.
Unless otherwise indicated, section references are to
applicable provisions of the Internal Revenue Code, Rule
references are to the Tax Court Rules of Practice and Procedure,
and dollar amounts are rounded.
1Respondent asserted in his amendment to answer that
petitioner failed to report $156,197 in gross receipts instead of
$77,550 as determined in the notice of deficiency, and he
asserted that the entire deficiency resulting therefrom was
attributable to fraud. Respondent did not set forth a specific
dollar amount for the increased deficiency or the fraud penalty,
stating that the amounts were computational.
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Last modified: May 25, 2011