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First-tier Second-tier
(initial) deficiency (additional) deficiency Addition to tax
Year Sec. 4975(a) Sec. 4975(b) Sec. 6651(a)(1)
1996 $1,016 -- $254.00
1997 3,252 -- 813.00
1998 6,941 -- 1,735.25
1999 10,999 -- 2,749.75
2000 15,463 -- 3,865.75
2001 -- $124,079 12,398.00
We decide whether petitioner is liable for these amounts. We
hold he is. Unless otherwise stated, section references are to
the applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the exhibits
submitted therewith. We find the stipulated facts accordingly.
Petitioner resided in Mentone, California, when his petition was
filed.
Aspects, Inc. (Aspects), is a C corporation of which
petitioner is the president and sole shareholder. It has a
profit sharing plan (plan) that was adopted effective December 1,
1983, and was amended on April 20, 1991. The plan is qualified
under section 401(a). The plan’s underlying trust is exempt from
Federal tax under section 501(a).
From the inception of the plan through November 7, 2001, the
date on which the notice of deficiency was issued in this case,
the plan has had many participants. One of these participants
was petitioner. Petitioner also was the plan’s sole trustee.
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