Gabriel Lopez - Page 2





                                                - 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.                                                                       






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