Wilburn C. Hall, Jr. - Page 3

                                        - 3 -                                         
                            Additions to Tax                                          
               Sec.             Sec.          Sec.           Sec.                     
          Year Deficiency1     6651(a)(1)  6653(a)(1) 6653(a)(2)   6661(a)            
          1982  $213,658       $53,415      $10,683           2                   $53,415
          1983   38,594         9,648         1,930           3                      9,135
          1984   27,901         6,975         1,395           2                      6,975
          1985   24,166         6,042         1,208           2                      6,042
                                              Sec.          Sec.                      
          6653(a)(1)(A)   6653(a)(1)(B)                                               
          1986    4,333         1,083          $217           2      --               
            1Of these amounts, $102 for 1983, $1,587 for 1985, and $438 for 1986 are self-
          employment taxes under ch. 2; the remainders are income taxes under ch. 1.  
          250 percent of the interest due on the entire deficiency for each year.     
          350 percent of the interest due on $36,540.                                 
          After concessions by both sides,2 the issues for decision                   
          are as follows:                                                             
          (1)  Whether a notice of deficiency for 1982 through                        
          1984 was mailed to petitioner at his last known address                     
          within the time limitation prescribed under section 6501.                   
          (2)  Whether petitioner had unreported Schedule C gross                     
          receipts for 1982, and, if so, in what amount.                              
          (3)  Whether petitioner had unreported interest income                      
          for 1984 through 1986, and, if so, in what amounts.                         







               2Respondent conceded the additions to tax for 1982 and the             
          $10,329 royalty income adjustment for 1982.  Respondent also                
          conceded $158,355 of the Schedule C gross receipts adjustment to            
          income for 1982. Petitioner conceded that he is entitled to                 
          claim an exemption for only one child for 1983.  Deemed                     
          concessions are discussed infra, in connection with the issues to           
          which the specific concessions relate.                                      



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