- 2 - other court, and this opinion shall not be treated as precedent for any other case. Petitioner fraudulently underpaid his Federal income taxes for 1992, 1993, and 1994 and subsequently agreed to the assessment of deficiencies for those years. Respondent then determined civil fraud penalties under section 6663. Despite petitioner’s stipulation, as well as the record’s independent demonstration that he filed fraudulent returns with intent to evade tax, petitioner contends that imposition of civil fraud penalties would be unfair. Thus, the issue for decision is whether respondent’s penalty determination should be sustained. We hold that it should. Background Most of the facts have been stipulated, and they are so found. We incorporate by reference the parties’ extensive stipulation of facts and accompanying exhibits. At the time that the petition was filed, Donald Ray Hartley resided in Jacksonville, Florida. In early 1995, petitioner told his brother-in-law that he needed someone to help him file several years’ worth of delinquent Federal income tax returns. Petitioner had not yet filed for those years because he knew he would owe money. Petitioner’s brother-in-law introduced him to a man named Robert Rudolph (Mr. Rudolph), who was then employed by thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007