Ara Eresian and Evelyn Eresian - Page 2

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               NIMS, Judge:  Respondent determined the following income tax           
          deficiencies, additions to tax, and penalty with respect to                 
          petitioners' 1988 and 1989 taxable years:                                   
                              Additions to Tax          Penalty                       
          Taxable             Sec.      Sec.           Sec.      Sec.                 
           Year   Deficiency  6651(a)(1)   6653(a)(1)    6661      6662(a)            

          1988     $28,495     $2,479      $1,425      $7,124       -0-               
          1989       4,550        -0-         -0-        -0-       $910               
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the years in            
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     
               After concessions, the issues for decision are:                        
               1.  Did petitioners have unreported income of $61,353 and              
          $4,666 for 1988 and 1989, respectively?                                     
               2.  Did petitioners have unreported interest income of $84             
          and $214 for 1988 and 1989, respectively?                                   
               3.  Did petitioners have a loss of $350,000 on the                     
          disposition of real estate in 1988?                                         















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