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Steven M. Kwartin, Martin J. Nash, Michael B. Axman, and
William J. Palmer, for petitioner.
Stephen R. Doroghazi and Kenneth A. Hochman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Jonathan B. Geftman petitioned the Court to
redetermine respondent's determination of a $13,043 deficiency in
his 1985 Federal income tax, a $3,261 addition thereto under
section 6651(a), and a $754 addition thereto under section
6654(a).1
We must decide:
1. Whether amounts paid to petitioner, as sole beneficiary
of a trust, are includable in his 1985 gross income. We hold
that a portion of the amounts is.
2. Whether petitioner is liable for an addition to tax
under section 6651(a). We hold that he is.
3. Whether petitioner is liable for an addition to tax
under section 6654(a). We hold that he is.
1 Respondent also determined that petitioner was liable for
additions to tax under sec. 6653(a)(1) and (2), but these
additions have been conceded by respondent.
Petitioner initially disputed only the additions to tax and
not the deficiency in tax. Later, in his amended petition,
petitioner contested the deficiency as well as the additions to
tax.
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