Eric B. Benson, et al. - Page 2

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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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