- 2 - Additions to Tax Year Deficiency Sec. 6651(f) Sec. 6654 1993 $192,457 $144,343 $8,064 1994 181,722 136,291 9,430 1995 122,177 91,633 6,625 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. The issues for decision involve the amount of unreported income that should be charged to petitioner, petitioner’s liability under section 6651(f) for fraudulent failure to file income tax returns, and petitioner’s liability under section 6654 for failure to make estimated income tax payments. FINDINGS OF FACT Because petitioner failed to respond to respondent's requests for admission, factual matter set forth in respondent's requests for admission is deemed admitted. See Rule 90(c). When the petition was filed, petitioner resided in Greenwell Springs, Louisiana. Petitioner and his stepdaughter and her husband, Rebecca and Richard Adair, operate a roofing business under the name H & H Sheet Metal (the roofing business). The evidence does not establish how ownership of the roofing business is divided between petitioner and the Adairs.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011