Walter L. Medlin - Page 76

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          involved the use of trustees, and petitioner agreed that those              
          particular transactions were taxable.  Petitioner did not inform            
          the revenue agent that proceeds from his real estate transactions           
          were deposited into Mr. Miles’s law firm’s trust account, nor did           
          he inform him of his belief that those proceeds were not subject            
          to taxation if not disbursed.  On April 27, 1988, this Court                
          entered a decision pursuant to a stipulation of the parties and             
          found the following deficiencies and additions to tax:                      
                              Additions to Tax                                        
          Tax                   Sec.         Sec.      Sec.        Sec.        Sec.   
          Year    Deficiency      6651(a)(1)    6653(a)  6653(a)(1)  6653(a)(2)     6661
          1977      $1,082          $2,240         $54      n/a          n/a         n/a
          1978      22,213          10,661       1,161      n/a          n/a         n/a
          1979      63,533          15,883       3,177      n/a          n/a         n/a
          1981       7,110           1,778         n/a     $356     50% interest      
                                                       on $7,110       n/a            
          1982      37,921           3,792         n/a    1,896     50% interest      
                                                       on $37,921   $9,480            
               Petitioner did not file timely his Forms 1040 for 1983 and             
          1984.  Those tax returns were filed on January 30, 1986, and                
          March 7, 1986, respectively.  Respondent examined those tax                 
          returns.  Petitioner told the revenue agent assigned to that                
          examination that he was not involved in any corporations,                   
          partnerships, or trusts.  Petitioner’s income for 1983 and 1984             
          was determined on the basis of deposits and disbursements from              
          his bank accounts.  The revenue agent explained to petitioner               
          that simply analyzing deposits into his bank account was not the            
          proper way to report income and did not reflect the true                    
          financial picture of his real estate transactions.  Petitioner              






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