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Additions to Tax/Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1996 $231,570.00 $57,892.50 $46,314.00
1997 519,659.00 29,914.75 103,931.80
1998 721,699.00 180,424.75 144,339.40
1999 605,972.00 90,895.80 121,194.40
2000 491,618.00 --- 98,323.60
Respondent determined the following deficiencies, additions
to tax, and penalties with respect to petitioner Mercury Solar
PTO (“Pure Trust Organization”)1:
Additions to Tax/Penalties1
Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6662(a)
1996 $203,496.6 $50,874.16 --- $40,699.32
1997 479,840.46 119,960.12 --- 95,968.09
1998 169,994.56 --- 135,995.64
1999 138,455.81 $26,574.40 110,764.64
2000 --- --- 87,532.24
1 Respondent also imposed a sec. 6651(a)(2) addition to
tax on Mercury Solar PTO for the 1999 tax year, in an
amount to be computed later.
1 For convenience, we use the term “trust” to reflect the
characterization of Mercury Solar PTO and Hawaii Environmental
Holdings (HEH) asserted by petitioners and set forth in formation
documents and business records. The use of this term (and of
related terms such as “trustee” and “beneficial owner”) is not
intended to be conclusive as to characterization for tax
purposes.
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Last modified: May 25, 2011