T.C. Memo. 1995-570
UNITED STATES TAX COURT
WALTER VAN ECK AND FRIEDGARD VAN ECK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8666-92. Filed November 29, 1995.
R determined deficiencies in income tax based in
part upon: (1) a bank deposit analysis for the years
1982 through 1987, and (2) the disallowance of a
deduction claimed in 1987. Respondent also determined
additions to tax under sec. 6651, I.R.C., for failure
to file, and sec. 6653(a), I.R.C., for negligence.
1. Held: Ps have in part carried and in part failed
to carry their burden of proving that the income items
in dispute were not gross income to them.
2. Held, further, R's determination of additions
to tax under sec. 6651, I.R.C., are sustained.
3. Held, further, R's determination of additions
to tax under sec. 6653(a), I.R.C., are sustained.
Walter Van Eck and Friedgard Van Eck, pro sese.
Catherine J. Caballero and Jeffery M. Wong, for respondent.
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