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deposit analysis for the years 1982 through 1987, and (3) the
disallowance of a deduction claimed in 1987. Petitioners filed a
single petition in response to both notices of deficiency. Prior
to and during the trial of this case, the parties entered into a
series of stipulations that resolved all adjustments associated
with the disposition of real property and substantially reduced
the amounts of bank deposits that are in dispute. On brief,
respondent has conceded that certain additional deposits
represent nontaxable items to petitioners and that the addition
to tax under section 6661 no longer is applicable. We accept
such concessions. Several items relating to respondent's bank
deposit analysis and the disallowed deduction remain for
decision, as do the additions to tax under sections 6651 and
6653.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. Our findings of fact and opinion for each issue are
set out separately.
PRELIMINARY FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact filed by the parties and attached
exhibits are incorporated herein by this reference.
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