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liable for the fraud penalty, pursuant to section 6663,1 for
taxable years 1992 through 1994, in the amounts of $4,242,
$44,931, and $8,406, respectively. Alternatively, respondent
determined that petitioners are liable for an accuracy-related
penalty, pursuant to section 6662(a), for the taxable years 1992
through 1994, in the amounts of $1,131, $11,982, and $2,242,
respectively. Petitioners concede the additional income
determined by respondent in the notice of deficiency and present
only the following issues for us to address: (1) Whether
petitioner is liable for the fraud penalty pursuant to section
6663 for 1992, 1993, and 1994; and (2) if the fraud penalty is
not applicable, whether petitioners are liable for the accuracy-
related penalty pursuant to section 6662(a) for 1992, 1993, and
1994.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts are incorporated herein by reference and are
found as facts in the instant cases. Petitioners resided in
California at the time they filed their petitions in the instant
cases.
1 Unless otherwise noted, 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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