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1. With respect to $146,193 of Elan’s income that
petitioner received but did not deposit in Elan’s bank accounts,
whether petitioner used $26,134 of that income to pay Elan’s
expenses as respondent contends; $120,059 as petitioner contends;
or some other amount. We hold that he used $26,134 to pay Elan’s
expenses.
2. Of the $120,059 of Elan’s income that petitioner did
not deposit in Elan’s bank accounts or use to pay Elan’s
expenses, whether all of it is taxable to petitioner, as
respondent contends, or only one-half of it is taxable to
petitioner, as petitioner contends. We hold that $120,059 is
taxable to petitioner.
3. Whether petitioner is liable for the addition to tax
under section 6651(a)(1) for failing to file a return for 1990.
We hold that he is.
4. Whether petitioner is liable for the addition to tax
under section 6654 for underpaying his estimated tax for 1990.
We hold that he is.
Section references are to the Internal Revenue Code in
effect for the year in issue. Unless otherwise stated, Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011