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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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Last modified: May 25, 2011