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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 taxable
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