- 2 - Accuracy- Related Additions to Tax Penalty Year Deficiency Sec. 6653(b)(1)(A) Sec. 6661(a) Sec. 6653(b) Sec. 6663 1986 $104,596 1$78,447 $26,149 ––- --- 1987 56,197 1 42,148 14,049 —–- --- 1988 50,951 —-- 12,737 $38,213 --- 1989 64,805 --- --- --- $48,604 1992 8,130 —-- —-- —-- --- 1Additionally, sec. 6653(b)(1)(B) imposes an addition of 50 percent of the interest due on the deficiency. Following a trial at which neither party presented any substantive evidence relating to respondent’s determinations, we must decide whether petitioner is liable for those amounts. We hold he is. Section references are to the Internal Revenue Code in effect for the subject years, and Rule references are to the Tax Court Rules of Practice and Procedure. Petitioner resided in New Jersey when his petition was filed. Background On November 21, 2000, respondent moved the Court under Rule 91(f) to issue an order directing petitioner to show cause why proposed facts in evidence should not be accepted as established. Three days later, the Court granted respondent’s motion and ordered petitioner to file with the Court by December 8, 2000, a response under Rule 91(f)(2) showing why the matters set forth in respondent’s motion papers should not be deemed admitted for purposes of this case. After petitioner failed to respond to the substance of our order, we ordered that the facts and evidence set forth in respondent’s motion papers be deemed established for purposes of this case.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011