- 2 - was liable for section 6663 fraud penalties of $4,909.50 for 1993, $8,682.75 for 1994, and $13,669.50 for 1995. (In the alternative to the fraud penalties, respondent asserted accuracy- related penalties under section 6662.) Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background On January 14, 1998, respondent issued to petitioners a statutory notice determining the above deficiencies and penalties. The deficiencies were based on respondent’s determination that petitioners realized unreported income from misappropriated or embezzled funds. On April 13, 1998, petitioners filed a petition with this Court disputing the notice of deficiency. Petitioners at that time resided in Cranston, Rhode Island. Respondent then answered the petition and further set forth specific allegations of fact in support of the fraud penalties, as follows: 6. FURTHER ANSWERING the petition, and in support of the respondent’s determination that, in regard to Petitioner Meri R. Kaufman, a part of the underpayments of tax required to be shown on petitioners’ joint income tax returns for the taxable years 1993, 1994 and 1995 is due to fraud, the respondent alleges: a. The Petitioner Meri R. Kaufman signed and filed joint returns with her husband for the 1993, 1994Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011