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Additions to Tax Penalty
Sec. Sec. Sec. Sec.
Sec. 6653 6653 6653 6653 Sec. Sec.
Year 6651 (b)(1) (b)(2) (b)(1)(A) (b)(1)(B) 6654 6663
1983 $0 $3,702 1 $0 $0 $423 $0
1984 0 3,785 1 0 0 349 0
1985 (1,263) 3,445 1 0 0 263 0
1986 (1,313) 0 0 4,225 1 250 0
1987 (987) 0 0 2,962 1 214 0
1988 (970) 2,911 0 0 0 251 0
1989 (1,874) 0 0 0 0 509 5,621
1990 (1,844) 0 0 0 0 485 5,533
1991 (311) 0 0 0 0 34 5,267
1 50 percent of the interest payable with respect to the portion
of the underpayment due to fraud.
All section references are to the Internal Revenue Code for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
The sole issue for decision is whether petitioner is liable
for the additions to tax and penalties for fraud.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in San Leandro, California.
In 1962, petitioner graduated from high school. From August
1962 to August 1966, petitioner served in the U.S. Air Force.
During his service, he worked as an electrician. During this
time, petitioner enrolled in college correspondence courses.
1 Petitioner’s only argument against the sec. 6654
additions to tax is that they are barred by the statute of
limitations because he is not liable for the additions to tax and
penalties for fraud.
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Last modified: May 25, 2011