- 118 - determination regarding the application of the self-employment tax to petitioner’s net earnings and the amounts he determined. II. Additions to Tax for Fraud Respondent determined additions to tax under section 6653(b) for petitioner’s 1985, 1986, 1987, and 1988 tax years. Section 6653(b), in effect for the tax years at issue, provided for additions to tax for underpayments of tax which are attributable to fraud. Section 6653(b)(1) and (2), in effect for petitioner’s 1985 tax year provided: SEC. 6653(b). Fraud.-- (1) In general.--If any part of any underpayment * * * of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment. (2) Additional amount for portion attributable to fraud.--There shall be added to the tax (in addition to the amount determined under paragraph (1)) an amount equal to 50 percent of the interest payable under section 6601-- (A) with respect to the portion of the underpayment described in paragraph (1) which is attributable to fraud, and (B) for the period beginning on the last day prescribed by law for payment of such underpayment (determined without regard to any extension) and ending on the date of the assessment of the tax (or, if earlier, the date of the payment of the tax). Section 6653(b)(1) and (2), in effect for 1986 and 1987, provided:Page: Previous 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 Next
Last modified: May 25, 2011