Lance Brown - Page 2

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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                  
               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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