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On March 20, 2002, respondent issued to petitioner a notice
of deficiency (notice) with respect to his taxable years 1990 and
1991. In that notice, respondent determined deficiencies in,
additions under section 6651(a)(1) to, and fraud penalties under
section 6663(a) on petitioner’s tax, as follows:
Addition to Tax Fraud Penalty
Year Deficiency Under Sec. 6651(a)(1) Under Sec. 6663(a)
1990 $69,655 $17,642.85 $52,241.25
1991 109,700 10,973.21 82,275.00
Respondent further determined in the notice that petitioner
has imputed dividend income for 1990 and 1991 under section 7872
of $7,089 and $7,670, respectively, as a result of the forgone
interest on petitioner’s outstanding loan balances with Duncan &
Associates during those respective years.
Respondent also determined in the notice that petitioner has
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corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimidate or impede any officer or employee of the
United States acting in an official capacity under this
title, or in any other way corruptly or by force or
threats of force (including any threatening letter or
communication) obstructs or impedes, or endeavors to
obstruct or impede, the due administration of this
title, shall upon conviction thereof, be fined not more
than $5,000, or imprisoned not more than 3 years, or
both, except that if the offense is committed only by
threats of force, the person convicted thereof shall be
fined not more than $3,000, or imprisoned not more than
1 year, or both. The term “threats of force”, as used
in this subsection, means threats of bodily harm to the
officer or employee of the United States or to a member
of his family.
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Last modified: May 25, 2011