John A. and Donna L. Rowe - Page 3




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                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.                                                                                                         






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