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Additions to Tax
Year Deficiency Sec. 6653(b) Sec. 6661 Sec. 6654
1985 $296,275.88 1$155,784.40 $74,056.47
1986 389,855.00 1169,812.76 97,463.75
1987 387,838.00 1290,878.50 $119.43
1 Plus 50 percent of the interest due on the portion of the
underpayment due to fraud under sec. 6653(b)(2) for 1985 and sec.
6653(b)(1)(B) for 1986 and 1987.
The issues for decision are:1
1. Whether petitioner failed to report income of $600,515
for 1985, $787,080 for 1986, and $1,008,325 for 1987. We hold
that he did.
2. Whether petitioner is liable for additions to tax under
section 6661 for substantial understatement of income tax of
$74,056.47 for 1985 and $97,463.75 for 1986. We hold that he is.
3. Whether petitioner is liable for the addition to tax
under section 6654 for failure to pay estimated tax of $119.43
for 1987. We hold that he is.
1 We previously held that petitioner is collaterally
estopped from denying that he is liable for the addition to tax
for fraud under sec. 6653(b) for 1985, 1986, and 1987 because he
was convicted of attempting to evade or defeat tax in violation
of sec. 7201 for those years. Wapnick v. Commissioner, T.C.
Memo. 1997-133; see United States v. Wapnick, 60 F.3d 948 (2d
Cir. 1995). In its opinion, the U.S. Court of Appeals for the
Second Circuit indicated that petitioner and his associates at
one time prepared the tax returns for an estimated 13 percent of
New York City’s taxi drivers. United States v. Wapnick, supra at
950.
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