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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years before
the Court, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions,1 the issues for decision are:
1. Whether petitioner had unreported income in the amounts
of $37,636.73 and $148,518.66 from the sale of stolen cars in the
taxable years 1966 and 1967, respectively;
2. whether petitioner had unreported dividend income of
$15,922.84 from Bud-N-Jan Stables, Inc. in taxable year 1967; and
3. whether petitioner is liable for the addition to tax for
fraud under section 6653(b) for each year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The Stipulation of Facts, Supplemental Stipulation of Facts, and
the exhibits attached thereto are incorporated herein by this
reference.
Henry Deletis, Jr. (petitioner) resided in Fayetteville,
North Carolina, at the time he filed his petition in this case.
Stolen Car Sales
Petitioner worked for Herbert J. Caplan, Inc., a Buick
dealership (the dealership), in Brooklyn, New York, for 14 years;
1 Petitioner has conceded interest income of $5.73 and $3.15
for the 1966 and 1967 taxable years, respectively, and wage
income of $12,324.95 for 1967. Respondent has conceded $10 of
the income from the stolen cars for taxable year 1967, so that
the claimed amount is $148,518.66 rather than $148,528.66.
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