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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.
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