- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Judge: Respondent determined the following deficiencies and penalties with respect to petitioner’s Federal income taxes for the taxable years 1993 and 1994: Taxable Income Tax Penalty Year Deficiency Sec. 6663 1993 $60,212 $45,159 1994 38,407 28,805 Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are: (1) Whether petitioner’s case should be dismissed for failure properly to prosecute with respect to the deficiencies determined by respondent; and (2) whether petitioner is liable for civil fraud penalties pursuant to section 6663. FINDINGS OF FACT Procedural Background On June 21, 1999, respondent issued to petitioner a statutory notice determining that petitioner was liable for deficiencies and fraud penalties for the 1993 and 1994 taxablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011