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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...)
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