- 2 - 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, arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011