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Penalty
Year Deficiency Sec. 6663
1991 $22,527 $16,895
1992 21,154 15,866
1993 5,096 3,822
1994 30,233 22,675
After concessions, the issues to be decided are:
(1) Whether petitioner is liable for the fraud penalty for
each of the years at issue;
(2) whether the doctrines of res judicata, collateral
estoppel, and/or double jeopardy bar the assessment of
deficiencies and penalties for all years at issue in an amount
greater than $61,700; and
(3) whether the period for assessing tax for the years at
issue has expired.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference.
Petitioner resided in Austin, Minnesota, on the date the
petition in this case was filed. During the years at issue,
petitioner farmed approximately 700 to 800 acres. He grew
soybeans, corn, and other crops. These crops were then sold to
various grain elevator companies and canneries in the area. In
addition, petitioner worked between 25 and 30 hours a week as a
theater manager/projectionist.
Erik Newhouse of Fast Income Tax and Computer Svc. prepared
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Last modified: May 25, 2011