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2. Whether Bradley T. Jacobsen (Mr. Jacobsen) had
unreported gross receipts of $28,378 in 1987 and $29,747 in 1988,
computed under the net worth method.
3. Whether Mr. Jacobsen had additional unreported income of
$6,285 in 1987 and $6,309 in 1988, on the basis of Bureau of
Labor Statistics figures.
4. Whether Mr. Del Bosque is liable for additions to tax
and/or a civil fraud penalty for 1988 and 1989.4
5. Whether Mr. Jacobsen is liable for an addition to tax
for fraud for 1988.5
6. Whether the period of limitations on assessment and
collection with respect to 1988 and 1989 expired before
respondent issued the subject notices of deficiency to
petitioners.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Mr. Del Bosque died on April 5, 2003, after the conclusion
of the trial in these cases. When the petitions in these cases
were filed, Mr. Del Bosque resided in Roseville, Minnesota,
4Mr. Del Bosque’s estate concedes that he is liable for the
addition to tax for fraud for 1987.
5Mr. Jacobsen concedes that he is liable for the addition to
tax for fraud for 1987.
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