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MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: These cases were consolidated for purposes of
trial, briefing, and opinion. Respondent determined deficiencies
in petitioners’ Federal income taxes, additions to tax pursuant
to section 6651(a)(1),2 accuracy-related penalties, and additions
to tax/fraud penalties pursuant to sections 6653(b) and 66633 for
the docket numbers, taxable years, and in the following amounts
as stated:
Eric B. Benson, Docket No. 585-98:
1Additions to Tax/Penalties
Year Deficiency Sec. 6651(a) Sec. 6663(a)
1993 $236,997 $59,793 $177,748
1Respondent asserts the accuracy related penalties as
an alternative in the event that the Court does not find
fraud.
Brad D. Benson, Docket No. 19416-98:
Penalty
Year Deficiency Sec. 6662(a)
1994 $43,906 $8,781
2All section references are to the Internal Revenue Code in
effect for the taxable years at issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
3In the notices of deficiency, respondent took an
alternative position that accuracy-related penalties pursuant to
sec. 6662(a) for the tax years 1989, 1990, 1993, and 1994 apply
to the extent additions to tax/fraud penalties do not. See also
infra note 70.
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