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* 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.
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Last modified: May 25, 2011