- 8 - obstructing and impeding respondent’s examination of petitioner with respect to its taxable years 1990 and 1991 and for the purpose of concealing from respondent the falsity of petitioner’s 1990 return and 1991 return. In Mr. Duncan’s March 31, 1998 plea agreement, Mr. Duncan also acknowledged that: (1) Petitioner’s 1990 return fraudu- lently understated petitioner’s income by $125,000; (2) peti- tioner’s 1991 return understated petitioner’s income by $150,000; and (3) petitioner’s accounting documents contained entries falsely reclassifying $125,000 of petitioner’s income for 1990 and $150,000 of petitioner’s income for 1991 as repayments by Mr. Duncan of loans allegedly drawn from petitioner’s “Loan to Shareholder” account. On March 20, 2002, respondent issued to petitioner a notice of deficiency (notice) with respect to its taxable years 1990 and 1991. In that notice, respondent determined deficiencies in, and fraud penalties under section 6663(a) on, petitioner’s tax, as follows: Fraud Penalty Year Deficiency Under Sec. 6663(a) 1990 $64,392 $48,294.00 1991 75,726 56,794.50 Respondent further determined in the notice that petitioner has imputed interest income for 1990 and 1991 under section 7872 of $7,089 and $7,670, respectively, as a result of the forgonePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011