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for the years 1977 and 1978, and therefore failed to report other
or miscellaneous income for those years in the respective amounts
of $2,000,536 and $2,926,612.
Relevant portions of the record include the following.
Petitioner admits that he sold interests in the S-J partnerships
during 1976 and 1977. Petitioner admits that he received
substantial amounts of cash from the sales proceeds of the
limited partnership interests in the S-J partnerships.
Petitioner cannot give an exact accounting of the amount of cash
so received, or the time he received the cash. He failed to
maintain books and records providing an accurate accounting of
the cash he received from these sales. Nevertheless, he admits
that he received "approximately $1,720,916". Petitioner admits
that he fraudulently failed to report "all or a substantial
portion of" the income he received during 1976 and 1977 from the
sale of limited partnership interests in the S-J partnerships.
Respondent seeks partial summary judgment as to the amount
of other or miscellaneous income for 1976 that she determined in
the notice of deficiency, $1,684,916.6 Petitioner's admissions
establish that over a 2-year period, during 1976 and 1977, he
received approximately $1,720,916 in commissions. However, these
6 In the notice of deficiency respondent listed the source of
payments by which she determined petitioner's unreported
commission income. It is a list of bank deposits referencing the
respective banks, account numbers, check numbers, check dates,
and amounts. The underlying documentation concerning these items
is not included in the record before us on this motion.
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