- 2 -
Additions to tax and penalties
Year Deficiency Sec. 6653(a) Sec. 6651(a)(1) Sec. 6662
1987 $1,197,033 $63,143.55 $269,331.98 --
1988 274,146 16,379.00 61,682.50 --
1989 10,253 -- 2,307.20 $2,050.60
1990 112,208 -- 25,247.25 22,441.60
1992 82,632 -- 18,592.68 16,526.40
1993 1,774 -- -- 354.80
1994 17,581 -- -- 3,516.20
1995 19,992 -- -- 3,998.40
1996 16,702 -- -- 3,340.40
1997 20,177 -- -- 4,035.40
After concessions, the issues remaining for decision are:
1. Whether petitioner’s bases in equipment he sold in 1987-
90 exceeded the amounts conceded by respondent (the basis issue).
We hold that they did not.
2. Whether petitioner is liable for: (a) Additions to tax
for negligence under section 6653(a) for 1987-88; (b) the
accuracy-related penalty under section 6662(a) for 1989-90 and
1992-97; and (c) additions to tax for failure to timely file
returns under section 6651(a) for 1987-90 and 1992. We hold that
he is.
3. Whether petitioner complied with requirements for
issuing subpoenas to several prospective witnesses. We hold that
he did not, and thus the subpoenas were not enforceable.
4. Whether the Court properly denied petitioner’s motions
to recuse the trial Judge and for a hearing on whether certain
conduct of respondent’s trial counsel was fraudulent. We hold
that those motions were properly denied.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011