§66631

MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge: By notice of deficiency dated March 31, 2010, respondent determined deficiencies in petitioners’ federal income tax and fraud penalties pursuant to section 66631 as follows: Year Deficiency § 6663 Penalty 1999 $72,896 $54,672.00 2000 92,891 69,668.25 1 Unless otherwise indicated, statutory references are to the Internal Revenue Code, Title 26 U.S.C.

MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined income tax deficiencies of $37,594 and $18,769, and fraud-penalties pursuant to section 66631 of $28,195.50 and $14,076.75, for petitioners' 2005 and IUnless otherwise indicated, section references are to the (continued...) SERVED May312011 || - 2 - 2006 tax years, respectively.

303 250,727.25 2000 153,165 114,874.00 The issues we must decide are: (1) Whether petitioner has substantiated the existence or amounts of any foreign tax credits for the taxable years 1997, 1998, 1999, and 2000; (2) whether respondent has established that petitioner is liable for the fraud penalty pursuant to section 66631 for taxable years 1997, 1998, 1999, and 2000; and (3) whether petitioner has established that she is not liable, in the alternative, for a penalty pursuant to section 6662(a)

de are: (1) Whether petitioner has substantiated the existence or amounts of any foreign tax credits for the taxable years 1997, 1998, 1999, and 2000; (2) whether respondent has established that petitioner is liable for the fraud penalty pursuant to section 66631 for taxable years 1997, 1998, 1999, and 2000; and (3) whether petitioner has established that she is not liable, in the alternative, for a penalty pursuant to section 6662(a).

6663 1991 $22,904 $4,580.80 n/a 1992 60,262 12,052.40 n/a After concessions, the issues we must decide are: (1) Whether petitioner Frank Black is liable for the fraud penalty pursuant to section 66631 for taxable years 1991 and 1992; (2) whether assessment of the deficiencies in income tax and penalties for the taxable years 1991 and 1992 is barred by the statute of limitations; (3) whether petitioners failed to report income of $107,082 and $160,706, respectively, on their 1991 and 1992 joint i

Respondent also determined that petitioners were liable for fraud penalties under - 2 - section 66631 for 1993, 1994, and 1995 of $22,410, $61,488.75, and $33,916.50, respectively.

MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined deficiencies in petitioner’s Federal income taxes and penalties pursuant to section 66631 as follows: 1Unless otherwise indicated, all section references are to (continued...) - 2 - Year Deficiency Penalty Sec.

Respondent issued petitioner a Notice of Deficiency (NOD) in which he determined that petitioner is liable for federal income tax deficiencies of $6,704, $24,067, and $11,223 and section 66631 fraud penalties of $5,028, $18,050, and $8,417 for taxable years 2015, 2016, and 2017 (years in issue), respectively.

However, they disagreed with the Commissioner’s proposed section 66631 civil fraud penalties for the years at issue and a section 6654(a) addition to 1 Unless otherwise indicated, statutory references are to the Internal Revenue Code, Title 26 U.S.C.

MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge: By notice of deficiency dated July 7, 2017, respondent determined deficiencies in the federal income tax of Midwest Medical Aesthetics Center (Midwest Medical) of $84,392, $146,529, $185,786, $161,409, and $85,982 and civil fraud penalties under Served 03/25/24 2 [*2] section 66631 of $63,021.75, $109,896.75, $139,339.50, $121,056.75, and $64,486.50 for tax years 2006, 2007, 2008, 2009, and 2010, respectively.

MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: By notice of deficiency dated January 19, 2016, respondent determined a deficiency of $139,249 in petitioner’s federal income tax for the 2012 taxable year (year in issue) and a civil fraud penalty under section 66631 of $100,022.

D OPINION WELLS, Judge: Respondent determined deficiencies in petitioners’ federal income tax and additions to tax and penalties for 2004–07 (years in issue) as follows: Served 11/30/22 2 [*2] Additions to Tax/Penalties Year Deficiency § 6651(a)(1) § 66631 2004 $39,865 $9,216 $29,899 2005 51,739 12,070 38,804 2006 60,979 14,448 45,734 2007 74,019 — 55,514 Unless otherwise indicated, all statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times, all r

The notice determined deficiencies of $10,990 for 2003, $19,461 for 2004, $14,210 for 2005, and $31,574 for 2006, as well as a fraud penalty under section 66631 for each year.

Respondent also determined penalties for fraud under section 66631 of $78,447.75, $46,.413.75, and $39,297.75 for 1991, 1992, and 1993, respectively, as well as additions to tax for fraudulent failure to file under section 6551(f) of $32,980.25 and $232,617.70 for 1994 and 1995, respectively.

sserts in the answer that Knutsen is liable for the fraud penalty under sec. 6663 for 2001 and 2002 and if not, for the accuracy-related penalty under sec. 6662. PLC, docket No. 27628-07 Addition to Tax Fraud Penalty Year Deficiency Sec. 6651(a) (1) Sec. 66631 1999 $5,748 $1,437 $4,311 2000 83,784 8,382 62,838 2001 32,403 3,240 . 24,302 2002 76,414 -0- 57,311 2Unless otherwise indicated, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to th

Respondent also determined penalties for fraud under section 66631 for 1994, 1995, and 1996 against Mark May (Mr.

Respondent also determined penalties for fraud under section 66631 for 1994, 1995, and 1996 against Mark May (Mr.

Individual Income Tax Return for the 1990 taxable year showing an increase in tax of $33,255, respondent determined a $26,050 fraud - 2 - penalty under section 66631 for petitioner’s 1990 taxable year.

MEMORANDUM FINDINGS OF FACT AND OPINION CHABOT, Judge: By separate notices of deficiency, respondent determined deficiencies in individual income tax and penalties under section 66631 (fraud) against petitioners as follows: 1 Unless indicated otherwise, all section and chapter references are to sections and chapters of the Internal Revenue Code of 1986 as in effect for the years in issue.

Choi (petitioner) understated income for the taxable year 1991; (2) whether petitioners understated income for the taxable year 1992; (3) whether petitioner is liable for the civil fraud penalty under section 66631 for the taxable years 1991; (4) whether petitioners are liable for an addition to tax for delinquent filing of their return for 1993; (5) whether petitioners are liable for self-employment tax on their earnings from Gene’s Modern Market; and (6) whether petitioners provided over one-h

MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: Respondent determined the following de- ficiencies in, and fraud penalties under section 66631 on, peti- tioners' Federal income tax (tax): 1 All section references are to the Internal Revenue Code in effect for the years at issue.

MEMORANDUM OPINION GERBER, Judge: Respondent determined a $122,460 income tax deficiency and a $91,845 fraud penalty under section 66631 for petitioner’s 1993 taxable year.