- 2 - liability. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background At the time of filing the petition, petitioners resided in Paoli, Pennsylania. Petitioner Hugh D. Summers’s Criminal Case and Amended 1989 Tax Return During 1992, petitioner Hugh D. Summers (Mr. Summers) pleaded guilty to conspiring to defraud the Internal Revenue Service (IRS) by concealing and diverting income in violation of 18 U.S.C. section 371 (2000). Mr. Summers acknowledged that he received unreported taxable income of $963,000 between 1982 and 1990. Mr. Summers was sentenced to 4 years’ probation and agreed to file an amended tax return for 1989. See United States v. Hugh D. Summers, No. 93-CR-35 (E.D. Pa.). Petitioners’ Previous Tax Court Case On May 24, 1993, petitioners filed an amended tax return for 1989, reporting an increase in their tax liability in the amount of $69,289. On November 8, 1993, respondent assessed petitioners the $69,289 shown on petitioners’ 1989 amended tax return. On June 1, 1995, respondent sent petitioners a notice of deficiency regarding negligence penalties for petitioners’ 1989 taxable year. Petitioners timely filed a petition with thisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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