- 2 -
Additions to tax
Deficiency Sec. 6651(a) Sec. 6653(a)(1) Sec. 6661
$31,101 $7,697 $1,766 $7,775
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
In an amendment to petition, petitioner alleged that the
income reported on his 1988 return should be reduced by $27,992
because he erroneously reported interest income that was earned
on funds that belonged to his wholly owned corporation, N.A.
Tours, Inc. In an amendment to answer to amendment to petition,
respondent asserted that an increased deficiency for 1988 arose
from (1) unreported income from theft of $986,856, dividend
income of $20,641, capital gains from real estate sales of
$107,021, and ordinary income from those sales of $2,638; and (2)
a change in petitioner’s filing status from single to married
filing separately. Respondent further asserted that the
additions to tax determined in the notice of deficiency under
sections 6651(a), 6653(a)(1), and 6661 for 1988 should apply to
the increased deficiency.
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