- 3 - not expired. Respondent shows as an issue whether petitioner is liable for the addition to tax for negligence or intentional disregard of rules and regulations under section 6653(a)(1) for each of the taxable years 1987 and 1988. However, petitioner introduced no evidence with respect to the addition to tax for negligence for these years and has made no argument with respect to such an issue on brief. We, therefore, assume that petitioner has conceded the addition to tax for negligence for each of the calendar years 1987 and 1988. FINDINGS OF FACT Some of the facts have been stipulated and are found accordingly. Petitioner, who resided in Minnetonka, Minnesota, at the time of the filing of his petition in this case, filed his Federal income tax return, Form 1040, for each of the calendar years 1982, 1983, 1984, 1987, 1988, and 1989. Petitioner's returns for each of the years 1982, 1983, 1984, 1987, and 1988 were prepared by a public accountant, June Myslajek. Each of these returns contained a Schedule C, Profit (or Loss) from Business or Profession, showing petitioner as a professional wrestler who operated under the name The Sheik. On the returns for each of the years 1982, 1983, 1984, 1987, and 1988 petitioner claimed business expense deductions on Schedule C, including air fares.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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