John Marretta - Page 2

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               that the distributions were taxable income and that he                 
               filed a false and fraudulent Federal income tax return                 
               with the intent to evade income tax for the 1994 tax                   
               year.                                                                  
                    Held, further,  R’s determination that P is liable                
               for penalties pursuant to sec. 6663, I.R.C., for the                   
               1992, 1993, and 1994 tax years is sustained.                           


               Robert Kenny, for petitioner.                                          
               Robert W. Mopsick, for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               NIMS, Judge:  Respondent determined penalties pursuant to              
          section 6663 for taxable years 1992, 1993, and 1994 of $6,347,              
          $22,350, and $28,454, respectively.  In the alternative,                    
          respondent determined that petitioner is liable for accuracy-               
          related penalties pursuant to section 6662(a).                              
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect at all relevant             
          times, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            









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