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no underlying documentation. Respondent's determination is,
therefore sustained as to the inclusion of unreported income from
an unknown source of $61,353 and $4,666 in 1988 and 1989,
respectively, unreported interest income in the amounts of $84
and $214 for 1988 and 1989, respectively, and the disallowance of
the $350,000 loss for 1988. Similarly, respondent's
determination is also sustained as to itemized deductions in the
amounts of $16,482 and $14,235 for 1988 and 1989, respectively,
and taxable Social Security benefits in the amount of $2,705 for
1988.
Respondent determined an addition to tax for late filing of
petitioners' income tax return for 1988 under section 6651(a)(1)
in the amount of $2,479. Petitioners filed their 1988 return,
the extended due date of which was October 15, 1989, on January
31, 1990. They have offered no explanation for this lateness.
Petitioners are, therefore, liable for the addition to tax for
late filing as determined by respondent.
Respondent also determined an addition to tax for
substantial understatement of income tax liability for 1988 under
section 6661 in the amount of $7,124. Because we have sustained
respondent's deficiency determination, petitioners'
understatement exceeds 10 percent of the amount required to be
shown on their return, and it also exceeds $5,000. Petitioners
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