- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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