- 4 - C. Taxable Year 1982 On June 12, 1989, respondent issued a notice of deficiency to petitioner determining a deficiency in and additions to his Federal income tax for 1982. On September 5, 1989, petitioner filed a timely petition with the Court (assigned docket No. 21830-89) contesting the notice of deficiency for 1982. On May 17, 1991, the Court entered a stipulated decision that petitioner was liable for a deficiency in income tax in the amount of $36,016, an addition to tax under section 6653(a)(1) in the amount of $1,800.80, an addition to tax under section 6653(a)(2) in an amount equal to 50 percent of the interest due on the deficiency, and an addition to tax under section 6661 for substantial understatement of liability in the amount of $9,004.00. Petitioner did not file any notice of appeal in docket No. 21830-89. Accordingly, the Court's decision in that docket has long been final. See secs. 7481(a)(1), 7483. D. Taxable year 1983 On June 15, 1990, respondent issued a notice of deficiency to petitioner determining a deficiency of $167,381 in his Federal income tax for 1983. Respondent also determined that petitioner was liable for additions to tax under section 6653(b)(1) and (2) for fraud and under section 6661 for substantial understatement of liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011