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The issues for decision are:
(1) Whether petitioner had unreported income for each of the
years under consideration (namely, 1990, 1991, and 1992), as
determined by respondent. In respondent's posttrial brief,
respondent concedes a portion of the taxable income determined in
the notice of deficiency. We hold that petitioner had unreported
income for each year under consideration in the amount determined
by respondent after concession, discussed infra.
(2) Whether petitioner's failure to file Federal income tax
returns for each of the years under consideration was due to fraud.
We hold that it was.
(3) Whether petitioner should be required to pay a penalty to
the United States under section 6673(a)(1). We hold that he
should, in the amount of $5,000.
All section references are to the Internal Revenue Code in
effect for the years under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure. All dollar
amounts are rounded.
FINDINGS OF FACT
Petitioner resided in Boise, Idaho, at the time he filed his
petition. He did not file a Federal income tax return for any of
the years under consideration.
Petitioner had been employed by the city of Boise (the City)
since 1977. During the years under consideration, he was a
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