James K. Roberts - Page 1

                                 T.C. Memo. 1996-225                                  


                               UNITED STATES TAX COURT                                


                           JAMES K. ROBERTS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No.  10322-93.              Filed May 16, 1996.                 


                    The issues for decision are (1) whether                           
               petitioner failed to report certain items of gross                     
               income, (2) whether he is entitled to certain                          
               disallowed Schedule C and Schedule A deductions, and                   
               (3) whether he is liable for certain additions to tax.                 
                    1.  Held:  Except for one item, P has failed to                   
               prove that the income items in dispute were not gross                  
               income to him.                                                         
                    2.  Held, further, P is not entitled to any of the                
               disputed deductions disallowed by R.                                   
                    3.  Held, further, R’s determination of the                       
               disputed addition to tax under sec. 6651, I.R.C., is                   
               sustained.                                                             
                    4.  Held, further, R’s determination of additions                 
               to tax under sec. 6653(a), I.R.C., is sustained.                       






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