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Civil Fraud
Additions to Tax Penalty
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A)6653(b)(1)(B)6653(b)(1) 6663
1987 $15,678 $12,451 1 --- ---
1988 10,153 --- --- $7,615 ---
1989 4,478 --- --- --- $3,359
1990 11,297 --- --- --- 8,473
1 50 percent of the interest due on $15,678 for taxable year 1987.
After concessions, the primary issues for determination are:
(1) Whether petitioners have unreported income for taxable years
1987, 1988, 1989, and 1990 as determined by respondent; (2)
whether petitioners are liable for self-employment tax on
unreported income for taxable years 1987, 1988, 1989, and 1990;
(3) whether petitioners are liable for additions to tax or
penalties for civil fraud for each of the taxable years 1987,
1988, 1989, and 1990; and (4) whether respondent is time barred
from assessing tax liability against petitioners for any of the
subject years.1
Unless otherwise noted, section references are to the
Internal Revenue Code as in effect for the relevant taxable
years. Rule references are to the Tax Court Rules of Practice
and Procedure.
1 Respondent’s determinations with respect to the recapture
of petitioners’ 1987 claimed earned income credit and with
respect to the reduction of petitioners’ 1989 and 1990 claimed
child care credits are automatic adjustments that will be
resolved by our decision of the primary issues.
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Last modified: May 25, 2011