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After settlement, the only issue for decision1 is whether
petitioner Howard Levine is liable for the fraud penalties for
1990, 1991, and 1992.2
Hereinafter, references to petitioner in the singular are to
Howard Levine. Unless otherwise indicated, all references to
sections are to the Internal Revenue Code, and all references to
Rules are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
At the time they filed their petition herein, petitioners
resided in Dix Hills, New York.
During 1990 through 1993, petitioner worked for his father’s
accounting firm as a bookkeeper and tax return preparer, and
1 Due to the fact that petitioner Linda Levine was unable to be
present to testify at the partial trial held on Dec. 5, 2000, we
have reserved for decision whether petitioner Linda Levine
qualifies for relief from liability under sec. 6015(b) for the
Federal income tax deficiencies and the fraud penalties under
sec. 6663 that respondent determined against petitioners
regarding their joint Federal income tax returns for 1990 through
1993.
2 With regard to 1993, petitioner Howard Levine’s liability for
the fraud penalty is established as a result of petitioner’s
guilty plea to criminal tax evasion under sec. 7201 for the same
year.
In the alternative to the fraud penalties determined by
respondent, respondent for each year also determined against
petitioners late filing additions to tax and negligence
penalties.
.
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Last modified: May 25, 2011