- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011