James Luther Cochrane - Page 2

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                    1.  Held:  Sanctions imposed; the matters                         
               contained in R's requested admissions are established                  
               for purposes of this case.                                             
                    2.  Held, further:  P had unreported taxable                      
               income as determined by R for each of the years in                     
               issue.  P is also liable for an addition to tax for                    
               fraud under sec. 6653(b), I.R.C., for each of the years                
               in issue, an addition to tax for substantial                           
               understatement of income tax under sec. 6661, I.R.C.,                  
               for 1984, and an addition to tax for failure to pay                    
               estimated tax under sec. 6654, I.R.C., for 1986.                       

               James Luther Cochrane, pro se.                                         
               Karen N. Sommers, for respondent.                                      


                                       OPINION                                        

               RUWE, Judge:  Respondent determined deficiencies in and                
          additions to petitioner's Federal income taxes as follows:                  

                         Additions to Tax                                             
           Year   Deficiency   Sec. 6653(b)(1)   Sec. 6653(b)(2)  Sec. 6661           
          1983     $3,264          $1,632       50 percent of        --               
          the interest due                                                            
          on $3,264                                                                   
          1984      6,767           3,384       50 percent of      $1,692             
          the interest due                                                            
          on $6,767                                                                   
          1985      2,133           1,067       50 percent of        --               
          the interest due                                                            
          on $2,133                                                                   
                          Additions to Tax                                            
           Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6654            
          1986   $2,884          $2,163      50 percent of the     $139               
          interest due on                                                             
          $2,884                                                                      




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