Gaylon L. Harrell, (1998)
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Gaylon L. Harrell, (1998)
T.C. Memo. 1998-207
UNITED STATES TAX COURT GAYLON L. HARRELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7339-95. Filed June 15, 1998.P did not file a Federal income tax return for 1991, 1992, or 1993. R determined deficiencies and additions to tax for each year. R filed a motion under Rule 40, Tax Court Rules of Practice and Procedure. This Court granted R's motion, in part, with respect to the deficiencies in income tax and additions to tax under secs. 6651(a)(1) and 6654, I.R.C., but denied the motion as to the issue of P's liability for the fraud addition to tax under sec. 6651(f), I.R.C. 1986, for 1993. 1. Held: P is liable for an addition to tax for fraud under sec. 6651(f), I.R.C. 1986, for 1993. 2. Held, further, P is liable for a penalty of $10,000 under sec. 6673, I.R.C. 1986.Gaylon L. Harrell, pro se.-2James A. Kutten, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION CHABOT, Judge: Respondent determined deficiencies in Federal individual income tax and additions to tax under sections 6651(a)(1)1 (failure to file), 6651(f) (fraud), and 66542(underpayment of estimated tax) against petitioner as follows:Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6651(f) Sec. 6654 1991 $3,436 $859 -- $113 1992 3,293 823 -- 79 1993 6,374 -- $2,868 269 -3After resolution of ...See the full content of this document
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