T.C. Memo. 1997-471
UNITED STATES TAX COURT
JOHN R. BOONE, JR., Petitioner, v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13909-96. Filed October 15, 1997.
On the facts, Held: R has proven, by a
preponderance of the evidence, that P improperly
omitted a substantial amount of gross income from his
Federal tax returns for 1989 and 1990 within the
meaning of sec. 6501(e)(1)(A), I.R.C., such that R is
not barred from assessing deficiencies for those years
by the 3-year statute of limitations of sec. 6501(a),
I.R.C. Held, further, P is not liable for self-
employment taxes pursuant to sec. 1401, I.R.C., on
gross income omitted from his returns for 1989 and
1990. Held, further, accuracy-related penalties for
negligence pursuant to sec. 6662(a), I.R.C., for 1989
and 1990 are sustained.
David W. Gray, for petitioner.
Aubrey C. Brown, for respondent.
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