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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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