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Joseph R. Rollins, pro se.
Denise G. Dengler, for respondent.
MEMORANDUM OPINION
CHABOT, Judge: Respondent determined deficiencies in excise
taxes under section 49751 (prohibited transactions) and additions
to tax under section 6651(a)(1) (failure to file tax return)
against petitioner as follows:
Year or Deficiencies Additions to Tax
Taxable Period Sec. 4975(a) Sec. 4975(b) Sec. 6651(a)(1)
1998 $5,231.80 --- $1,307.95
1999 14,576.97 --- 3,644.24
2000 24,448.50 --- 6,112.13
Period ending
Oct. 9, 2002 --- $164,228.39 ---
1 Unless indicated otherwise, all section and subtitle
references are to sections and subtitles of the Internal Revenue
Code of 1986 as in effect for the years and taxable period in
issue.
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