- 3 - year 1990. In the notices, respondent determined deficiencies in petitioner and Mr. Rowe’s Federal income taxes, additions to tax, and penalties as follows:3 Additions to Tax and Penalties Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661 1987 $173,817 $130,363 1 $43,454 Sec. 6653(b)(1) Sec. 6661 1988 53,937 $40,453 $13,484 -- Sec. 6651(a)(1) Sec. 6663 1989 73,279 $13,792 $54,959 -- Sec. 6654 Sec. 6662(c) 1990 124,891 $8,057 $24,978 -- 150 percent of the interest due on $173,817. Petitioner and Mr. Rowe timely filed petitions with this Court on September 27, 1993, and November 18, 1994, respectively, disputing all the determinations contained in the notices of deficiency.4 No claim for relief from joint and several liability was made in either of the petitions. Respondent filed corresponding answers to the petitions on November 29, 1993, and December 27, 1994, respectively, denying the allegations contained in the petitions. The two cases were subsequently consolidated for trial, briefing, and opinion. 3The fraud additions to tax pursuant to sec. 6653(b) for the taxable years 1987 and 1988 and the fraud penalty pursuant to sec. 6663 for the taxable year 1989 related only to Mr. Rowe. 4Petitioner resided in Florida at the time the petitions in this case were filed.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