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Additions to Tax
Sec. Sec. 6653 Sec. 6653
Year Deficiency 6651(f) (b)(1)(A) (b)(1)(B) Sec. 6653(b)(1)
1987 $6,083 N/A $4,562.25 1 N/A
1988 3,189 N/A N/A N/A $2,391.75
1989 29,501 $22,125.75 N/A N/A N/A
1990 1,909 1,431.75 N/A N/A N/A
150 percent of the interest due on $6,083
The issues for decision are: (1) Whether petitioner had
unreported taxable income during the years at issue, and (2)
whether petitioner is liable for additions to tax for fraud
(section 6653(b))1 and fraudulent failure to file (section
6651(f)).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Lakewood,
Ohio. During the years in issue petitioner’s sole source of
income was the sale of illegal drugs. Petitioner derived
sufficient taxable income from the illegal sale of controlled
substances to require the filing of a Federal income tax return
in each of the years in question. Petitioner did not file income
tax returns for the tax years 1987 through 1990.
On July 18, 1994, petitioner pleaded guilty to the felony
offence set out in section 72012 (Attempt to Evade or Defeat Tax)
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.
2Sec. 7201 provides:
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Last modified: May 25, 2011