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Deceased, and Donna M. Lisle, Deceased, for the taxable years
1984, 1987, and 1988.
In amended pleadings, respondent asserted increases in the
deficiencies in tax and additions to tax for the taxpayers and
years as follows: Burton W. and Naomi R. Kanter for the taxable
years 1978 to 1984 and 1986 to 1989; Claude M. and Mary B.
Ballard for the taxable years 1975 to 1982, 1984, and 1987 to
1989; and Estates of Robert W. Lisle, Deceased, and Donna M.
Lisle, Deceased, for the taxable years 1984 and 1987 to 1989.
In the amended pleadings referred to above, respondent asserted
that (1) the underpayments of tax with respect to all or
substantial portions of the increased deficiencies in tax are
subject to the addition to tax for fraud pursuant to section
6653(b);13 and (2) in the alternative, if the Court holds that
petitioners are not liable for additions to tax for fraud, then
petitioners are liable for additions to tax under sections
6653(a)(1) and (2) and 6659(a) and increased interest under
13 For 1976 through 1981, the addition to tax for fraud is
set forth in sec. 6653(b). For 1982 through 1985, the addition
to tax for fraud is set forth in sec. 6653(b)(1) and (2). For
1986 and 1987, the addition to tax for fraud is set forth in sec.
6653(b)(1)(A) and (B). For 1988, the addition to tax for fraud
is set forth in sec. 6653(b)(1). For 1989, the penalty for fraud
is set forth in sec. 6663(a). By prior agreement among the
parties at a pretrial conference with the Court, respondent’s
amended pleadings and petitioners’ replies thereto were not filed
of record until the commencement of trial; however, the parties
exchanged these filings with each other well before the trial
date that was set by the Court.
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