- 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.
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Last modified: May 25, 2011