- 2 - Held, further, Ps are liable for the additions to tax pursuant to sec. 6651(a)(1), I.R.C., for 1999 and 2000. Held, further, P-H is liable for the civil fraud penalty pursuant to sec. 6663, I.R.C., for 1999, 2000, and 2001. Mark and Erica Wright, pro sese.1 Stephen R. Takeuchi, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: This case is before the Court on a petition for judicial review of a notice of deficiency issued November 23, 2004, to both petitioners for their 1999, 2000, and 2001 taxable years. Respondent determined the following Federal income tax deficiencies, additions to tax, and penalties for petitioner Mark N. Wright’s (Mr. Wright) 1999, 2000, and 2001 taxable years:2 Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6663 1999 $34,194.00 $8,528.25 $25,645.50 2000 4,183.00 416.00 3,137.25 2001 10,495.00 -- 7,870.95 1Petitioners were represented by William Randolph Klein at trial, on briefing, and until his death on Nov. 27, 2006. 2Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011