- 8 - Additions to Tax and Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6663 1991 $14,505 –- $129,158 1992 43,026 2,307 299,461 1993 25,376 6,344 19,032 The deficiencies resulted from disallowed deductions for (1) commissions, fees, and contract labor expense consisting of payments to Mr. Fields’ co-conspirators and certain family members, and (2) travel and entertainment expenses. The notice of deficiency also provided that the accuracy-related penalty under section 6662 (for negligence or disregard of rules or regulations) would apply in the event the fraud penalty did not apply. Petitioner’s Counsel In August 1999, petitioner’s present counsel, Lawrence Sherlock, notified petitioner and Mr. Fields (who by that time had divorced) that he could no longer jointly represent them in view of their conflicting interests with regard to the fraud issue, as evidenced by the Appeals officer’s June 2, 1999, settlement offer. Petitioner and Mr. Fields agreed that Mr. Sherlock would continue to represent petitioner and that Mr. Fields would retain separate counsel.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