- 9 - at or about the times that they filed these returns with the IRS. At the times that petitioner signed these returns, she was aware that each return showed a substantial tax liability and that the total tax liabilities reported on these returns exceeded $500,000. After petitioner and intervenor filed their joint income tax returns for 1990 through 1995, the IRS determined additions to tax under sections 6651(a)(1), (2), and 6654 and interest with respect to the tax liabilities reported on these returns. The additions to tax were determined in the following amounts: Year Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654 1990 $18,189 $17,904 $5,261 1991 8,017 8,907 2,049 1992 11,153 10,906 2,132 1993 18,959 13,060 –- 1994 45,022 19,009 5,306 1995 –- 2,464 4,451 Petitioner and intervenor were aware that they would be liable for additions to tax and interest at the times that they signed the joint income tax returns for 1990 through 1995. Prior to signing these returns, however, petitioner and intervenor decided that they would request that the IRS abate any additions to tax. Accordingly, they did not pay any amounts in excess of the income tax liabilities reported on the joint income tax returns for 1990 through 1995 at the times that they filed these returns. Petitioner did not question intervenor at or before the times that she signed these returns as to how and when the additions toPage: 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