- 2 -
Year Deficiency 6651(a)(1) 6651(a)(2) 6651(f) 6654(a)
1999 $75,888 - $18,972 $55,018.80 $3,672.67
2000 69,302 - 2 51,976.50 3,701.75
2001 52,823 - 3 39,617.25 2,111
2002 44,220 $11,055 - - 1,477.71
The issues we must decide are: (1) Whether the record in the
instant case should be reopened to receive new evidence; (2)
whether petitioner has a zero basis in his S corporation stock;
(3) whether petitioner is liable for deficiencies in income tax
for taxable years 1999 through 2002; (4) whether petitioner is
liable for the fraud penalty pursuant to section 6651(f)4 for
taxable years 1999, 2000, and 2001; (5) whether petitioner is
liable for an addition to tax pursuant to section 6651(a)(1) for
failure to file his 2002 tax return; (6) whether petitioner is
liable for an addition to tax pursuant to section 6654(a) for
failure to make estimated payments for tax years 1999 through
2002; and (7) whether petitioner is liable for a penalty pursuant
to section 6673.
2To be calculated.
3To be calculated.
4Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in issue.
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Last modified: May 25, 2011