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Additions to Tax Penalties
Sec. 6653 Sec. 6653 Sec. Sec.
Year Deficiency (a)(1) (b)(1) 6663 6662(a)
1988 $25,632 $749 $7,987 – --
1989 42,187 -- – $17,709 $2,622
1990 56,315 -- – 31,889 2,580
1991 23,063 -- – 3,650 3,319
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. All figures are rounded to the nearest dollar.
The primary issue for decision is whether petitioner is
liable for the addition to tax and penalties for fraud based on
unreported income from her law practice. Additional issues are
whether (1) petitioner is entitled to certain Schedule C, Profit
or Loss From Business, deductions; (2) petitioner is entitled to
certain Schedule E, Supplemental Income and Loss, losses; and (3)
petitioner is liable for additional self-employment tax.
FINDINGS OF FACT
As made absolute by the Court’s orders dated December 6,
2002, and February 3, 2003, some of the facts have been deemed
stipulated and are so found. The first stipulation of facts, the
second stipulation of facts, and the attached exhibits are
incorporated herein by this reference. At the time she filed the
petition, petitioner resided in Corona, California.
Petitioner’s Education and Legal Background
On June 15, 1971, petitioner received a bachelor of arts
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