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Additions to Tax, I.R.C., Sections
Year Deficiency 6654 6653(b)(1)(A) 6653(b)(1)(B) 6651(f)
1987 $14,635 $785.65 $10,976.25 * --
1988 11,655 749.70 8,741.25 * --
1989 6,096 412.26 -- -- $4,572.00
1991 10,309 589.18 -- -- 7,731.75
1992 30,987 1,351.52 -- -- 23,240.25
1993 38,523 1,614.10 -- -- 28,892.25
1994 18,572 963.71 -- -- 13,929.00
1995 12,458 675.47 -- -- 9,343.50
1996 26,862 1,429.74 -- -- 20,146.50
1997 4,033 215.76 -- -- 3,024.75
* 50 percent of the interest on the deficiency.
Respondent also determined additions to tax under section 6663
for 1987 and 1988 but has now conceded that those additions to
tax are not due. Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure. The issues for decision are
whether petitioner’s underpayment of taxes and failure to file
tax returns for the years in issue were due to fraud and whether
a penalty should be awarded under section 6673 by reason of
petitioner’s groundless and frivolous positions maintained in
this proceeding.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in New Smyrna Beach, Florida, at the time that
he filed his petition.
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