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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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