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Additions to Tax
Sec. 6651 Sec. Sec. 6653 Sec. 6653 Sec. 6653 Sec.
Year Deficiency (a)(1) 6651(f) (b)(1)(A) (b)(1) (b)(1)(B) 6654
1986 $54,593 --- --- $40,945 --- 1--- ---
1987 73,676 --- --- 55,257 --- 2--- $2,791
1988 85,992 --- --- --- $64,494 --- 5,158
1989 132,429 --- $94,988 --- --- --- 8,522
1990 40,064 $8,650 --- --- --- --- 2,238
1991 14,052 1,961 --- --- --- --- 412
1992 91,232 21,592 --- --- --- --- 3,427
1993 20,040 4,896 --- --- --- --- 818
1994 3,515 879 --- --- --- --- 182
1995 3,371 843 --- --- --- --- 186
150 percent of the interest due on $49,421.
250 percent of the interest due on $68,449.
If we do not sustain respondent's determination of additions
to tax for fraud pursuant to sections 6653(b)1 and 6651(f) for
the years 1986 through 1989, respondent alternatively determined
the following additions to tax for negligence or intentional
disregard of rules and regulations (section 6653), and failure to
file within the time prescribed by law (section 6651):
Additions to tax
Sec. 6651 Sec. 6653 Sec. 6653
Year (a)(1) (a)(1)(A) (a)(1)
1986 $12,355 $2,730 ---
1987 17,112 3,684 ---
1988 20,296 --- $4,300
1989 31,663 --- ---
1Unless 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.
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Last modified: May 25, 2011