Henry Deletis, Jr. - Page 2

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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               
               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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