-2-
Additions to Tax
Years Deficiencies Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1994 $1,449 $333.50 -- --
1995 2,711 669.75 -- $146.01
1996 2,573 505.12 $527.57 117.51
Section references are to the applicable versions of the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
We decide:
1. Whether petitioner had unreported income of $15,287,
$24,471, and $23,701 determined by respondent for the respective
years. We hold he did.
2. Whether petitioner is liable for the additions to tax
determined by respondent under section 6651(a)(1). We hold he
is.
3. Whether petitioner is liable for the addition to tax
determined by respondent under section 6651(a)(2). We hold he
is.
4. Whether petitioner is liable for the additions to tax
determined by respondent under section 6654(a). We hold he is.
5. Whether we shall impose a penalty on petitioner under
section 6673 for advancing frivolous and/or groundless claims.
We shall impose a penalty of $10,000.
FINDINGS OF FACT
Some facts have been stipulated. The parties’ stipulation
of facts and the exhibits submitted therewith are incorporated
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011