- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011