John W. Marsh - Page 2






                                                    - 2 -                                                       

                                                                                                               
                                    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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