Adnan Al Kaissy - Page 3

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            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.                                                                                     





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