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additions to tax with respect to petitioners’ Federal income
taxes:
Vortex Products Corp. (Vortex), docket No. 24646-95
Addition to Tax Penalty
FYE Sept. 30 Deficiency Sec. 6651(f)2 Sec. 6663
1991 $ 28,813 $21,610
1992 85,831 64,373
1993 77,968 $58,476
Sam and Anna Zhadanov (the Zhadanovs), docket No. 14021-95
Penalty
Year Deficiency Sec. 6663
1990 $35,031 $26,273
1991 61,862 46,397
1992 77,522 58,142
Anna Zhadanov
Penalty
Year Deficiency Sec. 6663
1993 $60,272 $45,204
Sam Zhadanov, docket No. 24647-95
Penalty
Year Deficiency Sec. 6663
1993 $43,048 $32,286
Alternatively, respondent also determined that Vortex was liable
for the addition to tax under section 6651(a) if we conclude that
Vortex is not liable for the penalty under section 6651(f) for
its FYE 1993 and that the Zhadanovs were liable for accuracy-
related penalties under section 6662(a) if we conclude that they
2Unless otherwise indicated, all section references are to
the Internal Revenue Code for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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