Darlow T. Madge - Page 2




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                 Additions to Tax and Penalties                                       
          Year   Deficiency   Sec. 6651(f)   Sec. 6653(b)(1)(A)   Sec. 6654           
          1987    $59,607          -0-           $44,705.79       $3,199.79           
          1988     57,101          -0-            42,825.75        3,672.94           
          1989     70,534      $52,900.50            -0-           4,770.17           
          1990     68,450       51,337.50            -0-           4,481.53           
          1991     74,079       55,559.25            -0-           4,233.69           
          1992     88,708       66,531.00            -0-           3,869.04           
          1993     69,563       52,172.25            -0-           2,914.65           
          Respondent also determined an addition to tax under section                 
          6653(b)(1)(B) for 1987.  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.                                            
               Throughout these proceedings, petitioner has maintained only           
          frivolous positions.  To the extent that his voluminous                     
          submissions are intelligible, he contends that he is not a                  
          taxpayer, that his income from sale of hospital supplies is not             
          an item of income taxable under section 61, and that the                    
          regulations promulgated under section 61 provide that only                  
          foreign income is taxable.  Petitioner has maintained these                 
          positions despite having been convicted of tax evasion under                
          section 7201 for 1990, 1991, 1992, and 1993 and of conspiracy to            
          obstruct and impede the Internal Revenue Service (IRS) under 18             
          U.S.C. sec. 371.                                                            
               Petitioner failed to present any evidence that the amounts             
          of income and deductions determined in the statutory notice are             





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