Walter L. Medlin - Page 30

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          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:                                                                   








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