- 2 - * 50 percent of interest due on portion of underpayment attributable to fraud. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1986 and 1987, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the only issue for decision is whether petitioner is liable for the fraud additions to tax. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioner resided in Fort Lauderdale, Florida. During 1986 and 1987, petitioner was engaged in business as a self-employed loan broker. Petitioner’s business involved arranging for loans between finance companies and small business borrowers. On loans he arranged, petitioner typically received commissions from finance companies and fees from borrowers. During 1986 and 1987, petitioner received total commissions from finance companies of $28,695 and $22,086, respectively, and total fees from borrowers of $3,553 and $15,080, respectively. Except for one finance company, none of the finance companies from whom petitioner received commissions in 1986 and 1987 issued to petitioner Forms 1099 reflecting commissions paid to petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011