- 2 - Benson S. Goldstein, for petitioners. Judith C. Cohen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CHABOT, Judge: Respondent determined deficiencies in individual income tax and additions to tax under sections 66631 (fraud) and 6662(a) (negligence) against petitioners as follows: Additions to Tax Year Deficiency Sec. 6662(a) Sec. 6663 1991 $3,910 -- $2,933 1992 7,686 -- 5,765 1993 2,968 $594 -- 1Unless indicated otherwise, all part and section references are to parts and sections of the Internal Revenue Code of 1986 as in effect for the years in issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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