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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