- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011