Willis Clark - Page 2




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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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