T.C. Memo. 2007-50
UNITED STATES TAX COURT
MARK N. WRIGHT AND ERICA Y. WRIGHT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3276-05. Filed March 5, 2007.
Ps established offshore entities, and an offshore
bank account and credit card, that they used to conceal
unreported income. Ps also understated their S
corporation’s income and failed to include in their
income distributions from the S corporation that
exceeded their basis.
R determined deficiencies for 1999, 2000, and
2001, and additions to tax pursuant to sec. 6651(a)(1),
I.R.C., for 1999 and 2000. R determined civil fraud
penalties for P-H pursuant to sec. 6663, I.R.C., for
1999, 2000, and 2001. In the alternative to liability
for sec. 6663, I.R.C., R determined accuracy-related
penalties for Ps pursuant to sec. 6662, I.R.C., for
1999, 2000, and 2001.
Held: R’s deficiency determinations for 1999,
2000, and 2001, are sustained.
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