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Docket No. 23041-96
Accuracy-
Additions to tax related
Delinquency Negligence penalty
Year Deficiency Sec. 6651(a)(1)1 Sec. 6653(a)(1) Sec. 6662(a)
1988 $59,032 1$14,758 $3,210 --
1989 72,150 118,038 -- $14,430
1990 83,595 120,899 -- 16,719
1Respondent determined that petitioner was liable for the
addition to tax under sec. 6651(a)(1) for each of the years 1988-
90 in an amended answer. Respondent, therefore, bears the burden
of proof with respect to the imposition of the sec. 6651(a)
addition to tax for those years. Rule 142(a).
Docket No. 23054-96
Delinquency Negligence
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1)
1987 $55,459 $13,865 1$2,773
1For 1987, in addition to imposing the 5-percent negligence
addition to tax under sec. 6653(a)(1)(A), respondent also imposed
an addition to tax equal to 50 percent of the interest due on the
tax deficiency of $55,459. See sec. 6653(a)(1)(B).
Petitioner timely filed petitions seeking a redetermination
of respondent’s adjustments for 1987-90. We consolidated the
resulting cases for purposes of trial, briefing, and opinion,
1Unless 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. Some monetary amounts have been rounded to the
nearest dollar.
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