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tax, and penalties with respect to each petitioner’s Federal
income taxes:1
Robert L. Beck
Additions to Tax Penalties
Year Deficiency Sec. 6651(a)(1) 1Sec. 6663(a)
1991 $50,232 $12,558 $37,674
1992 50,051 12,513 37,538
1993 58,916 14,729 44,187
1994 83,789 20,947 62,842
1995 79,636 23,049 59,727
1 The notice of deficiency states that if “it is
determined the underpayment is not due to fraud, then
the accuracy related penalty per Internal Revenue Code
Section 6662(a) would be applicable.”
Marguerite Beck
Additions to Tax
Year Deficiency 1Sec. 6651(f) Sec. 6654(a)
1991 $43,671 $32,753 $2,496
1992 41,045 30,784 1,790
1993 50,049 37,537 2,097
1994 68,890 51,667 3,575
1995 76,387 57,290 4,142
1 The notice of deficiency states that if “it is
determined the failure to file is not due to fraud,
then the delinquency penalty rate of 25 percent, per
Internal Revenue Code Section 6651(a) would be
applicable.”
In his answer to Robert L. Beck’s (Dr. Beck’s) petition,
respondent conceded the fraud penalties under section 6663(a) for
1 Unless 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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Last modified: May 25, 2011