- 7 - $14,881 of additional interest income. Of the $14,881 of additional interest income, the Fieldses reported that $13,881 derived from BIC’s commercial checking account. The Fieldses paid the resulting additional tax of approximately $500,000 (approximately $150,000 for 1991 and $350,000 for 1992) with the amended returns, apparently deriving approximately $450,000 of such amount from refunds of erroneous FFI estimated tax payments, including FFI’s $300,000 1992 estimated tax payment. Conclusion of Respondent’s Examination In February 1997, the revenue agent notified the Fieldses that, for 1991, 1992, and 1993, she proposed (1) a reduction of business expense deductions for all 3 years, (2) the fraud penalty for 1991 and 1992, and (3) certain other penalties. The case then went to respondent’s Appeals Office. As part of a written settlement offer dated June 2, 1999, respondent’s Appeals officer offered to concede 25 percent of the fraud penalty. The Appeals officer characterized such proposed concession as a 50-percent concession of petitioner’s 50-percent share of the penalty. The Fieldses rejected that offer. By notice of deficiency dated July 29, 1999, respondent determined deficiencies, additions to tax, and penalties with respect to the Fieldses’ income taxes for 1991, 1992, and 1993 as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011