Derwyn Joseph Booker - Page 2

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                                                                                       Additions to Tax                                                                                                              
                                                                           Sec.                                 Sec.         Sec.                                                                                    
                         Year1   Deficiency                                6653(a)(1)  6653(a)(2)      6659                                                                                                          
                         1980     $4,898.17 $244.91                                                                2                     $1,469.45                                                                   
                         1981      5,791.00  289.55                                                                2                     1,737.30                                                                    
                         1982                     934.83   46.74                                                   2                     --                                                                          
                         1983                     6,108.00  305.40                                                 2                     1,832.40                                                                    

                                     1 Increased interest under sec. 6621(c) was imposed.                                                                                                                            
                                     2 50 percent of the interest payable with respect to the2                                                                                                                                                                              
                         portion of the underpayment attributable to negligence.                                                                                                                                     
                                     After concessions, the issues for decision are:                                                                                                                                 
                                     (1) Whether petitioner is entitled to claimed deductions                                                                                                                        
                         and a claimed investment tax credit for taxable year 1983 in                                                                                                                                
                         connection with his participation in the Century Concepts, Inc.,                                                                                                                            
                         Master Video Game Leasing Program.  We hold that he is not.                                                                                                                                 
                                     (2) Whether petitioner is liable for the negligence                                                                                                                             
                         additions to tax under section 6653(a)(1) and (2) for the taxable                                                                                                                           
                         years at issue.  We hold that he is.                                                                                                                                                        
                                                                                      FINDINGS OF FACT                                                                                                               
                                     Some of the facts have been stipulated and are found                                                                                                                            
                         accordingly.  The stipulation of facts and the attached exhibits                                                                                                                            
                         are incorporated herein.  Petitioner resided in Corpus Christi,                                                                                                                             
                         Texas, at the time the petition was filed in the instant case.                                                                                                                              
                                     In 1983, petitioner participated in the Century Concepts,                                                                                                                       
                         Inc. Master Video Game Leasing Program.  In 1983, Century                                                                                                                                   
                         Concepts, Inc. (Century Concepts or Century), was ostensibly in                                                                                                                             





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