- 2 -
Addition to Tax Penalty
Year Deficiency Sec. 6653(b) Sec. 6663
1988 $35,523 $26,642 ---
1989 17,502 --- $13,127
1990 29,203 --- 21,902
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The deficiencies were based on respondent’s determinations
that petitioner failed to report income of $93,374 in 1988,
$52,543 in 1989, and $78,253 in 1990. At trial, respondent
conceded that petitioner’s unreported income should be reduced by
$10,997 in 1990 to reflect items that respondent inadvertently
double counted. We sustain respondent’s deficiency
determinations, as adjusted, and the fraud addition to tax and
penalties applicable thereto.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the related exhibits are
incorporated by this reference.
Petitioner, who is also known as David Wu, resided in Palo
Alto, California, when he filed his petition.
During the years at issue, petitioner owned at least 30
percent of Palo Alto Computer, doing business as Palo Alto
Microsystems (PAC), a subchapter C corporation. The record does
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