Delwin D. Houser - Page 2




                                        - 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.                               








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