- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Respondent determined the following deficiencies in, additions to, and penalties on petitioners’ Federal income taxes: Petitioner Terrell Equipment Co., Inc.: Additions to Tax Penalty Tax Year Sec. 6653 Sec. 6653 Sec. 6653 Sec. Ended Deficiency (b)(1)(A) (b)(1)(B) (b)(1) 6663 9/30/87 $162,029 $121,522 1 --- --- 9/30/88 65,423 --- --- $49,067 --- 9/30/89 84,891 --- --- --- $63,668 1 50 percent of the statutory interest on $162,029 Petitioners Vernon W. Griffin and Janet M. Griffin: Additions to Tax Penalty Sec. 6653 Sec. 6653 Sec. 6653 Sec. Year Deficiency (b)(1)(A) (b)(1)(B) (b)(1) 6663 1987 $56,169 $42,127 1 --- --- 1988 50,696 --- --- $38,022 --- 1989 33,994 --- --- --- $25,496 1 50 percent of the statutory interest on $56,169 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The primary issue for decision is whether petitioners are liable for the additions to tax and penalties for fraud.3 If we 3 Sec. 6653(b)(1), the successor to sec. 6653(b)(1)(A) and (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011