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(b) what is the amount of petitioner’s unreported
gross income.
(3) For 1986--
(a) whether petitioner is liable for civil fraud
additions to tax under subparagraphs (A) and (B) of
section 6653(b)(1) and, as to subparagraph (B) of
section 6653(b)(1), in what amount.
(b) what is the amount of petitioner’s unreported
gross income.
(c) whether petitioner qualifies for innocent
spouse treatment under section 6013(e).
(4) For 1987, whether petitioner overstated an
itemized interest deduction by $8,559.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and
the stipulated exhibits are incorporated herein by this
reference.
When the petitions were filed in the instant cases,
petitioner resided in Chevy Chase, Maryland.
Background
Petitioner is a sophisticated taxpayer. Petitioner is a
practicing attorney; he holds a J.D. degree from the University
of Florida and an LL.M. in Taxation degree from New York
University. Petitioner was a senior trial attorney in the Trial
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