Robert G. Honts - Page 4

                                                    4                                                      
                  On the same day he filed the Form 2848 for taxable year                                  
            1987, petitioner filed a Form 872 (Consent to Extend the Time to                               
            Assess Tax) extending the time for assessment for his 1987 tax                                 
            year until April 15, 1993.  On the Form 872, petitioner listed                                 
            his residence as the Mansfield address.  On January 15, 1993,                                  
            petitioner filed his 1989 and 1990 Federal income tax returns,                                 
            listing his residence as the Mansfield address on the 1989 return                              
            and as 2300 Lohman's Crossing, Suite 190, Austin, Texas 78734                                  
            (the Lohman address) on the 1990 return.  The Lohman address is                                
            the location of petitioner's business office.                                                  
                  On April 9, 1993, respondent mailed a notice of deficiency                               
            determining the following deficiencies in, and additions to,                                   
            petitioner's Federal income taxes for years 1984, 1986, and 1987:                              
                                            Additions to Tax                                               
            Sec.         Sec.        Sec.         Sec.                                                     
            Year  Deficiency   6651(a)(1)   6653(a)(1)  6653(a)(2)    6661(a)                              
            1984   $64,118         --          $3,206       1         $16,030                              
                                             Additions to Tax                                              
            Sec.         Sec.         Sec.        Sec.                                                     
            Year  Deficiency   6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a)                              
            1986    $5,973         --          $299         1          $1,493                              
            1987    55,867      $12,061       2,793         1          13,967                              
            1  50 percent of the interest computed on the portion of the underpayment which1                                                                                             
            is attributable to negligence or intentional disregard of rules and regulations.               
            Respondent's adjustments to petitioner's 1984 and 1986 taxable                                 
            years are entirely the result of respondent's disallowance of                                  
            petitioner's NOL for 1987.  The notice of deficiency was mailed                                
            by certified mail to petitioner at the following addresses: (1)                                





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