- 2 - Fraud Penalty Year Deficiency Sec. 6663(a) 1995 $4,025 $3,019 1996 21,271 15,954 After concessions, the principal issue remaining for decision is whether petitioner is liable for the civil fraud penalty under section 6663(a). FINDINGS OF FACT The parties have stipulated many facts, which we incorporate herein by this reference. When he filed his petition, petitioner resided in Sewaren, New Jersey. Background In 1981, petitioner obtained an undergraduate degree in industrial engineering from Rutgers University. In 1985 he began working for the Internal Revenue Service as a valuation engineer, a position that he held during the years at issue. In 2000, as a result of the troubles described below, petitioner resigned his position with the Internal Revenue Service. Fictitious Government Investment Program Petitioner has been described as a compulsive gambler. On one of his periodic gambling trips to Las Vegas, Nevada, petitioner falsely represented to a longtime friend, Roy Kieffer, and various Kieffer family members (collectively, the Kieffers) that he could invest money for them in a Federal employee investment program, called “Stopgap Investments”, with aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011