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Section Section Section Section
Year Deficiency 6653(b)(1)(A)1 6653(b)(1)(B) 6653(b)(1) 6663(a)
1987 $23,437 $10,037 * -- --
1988 25,077 -- -- $13,613 --
1989 16,082 -- -- -- $8,189
1990 25,676 -- -- -- 16,498
1991 4,021 -- -- -- --
* 50 percent of the interest due on the portion of the underpay-
ment attributable to fraud. Respondent determined that $13,383
of the underpayment for 1987 was attributable to fraud.
The issues remaining for decision are:
(1) Is petitioner Haralampos Katerelos (Mr. Katerelos)
liable for 1987 and 1988 for the additions to tax for fraud under
section 6653(b)(1) and for 1989 and 1990 for the penalties for
fraud under section 6663(a) on the portion of the underpayment
for each of those years that is attributable to his not reporting
certain gross receipts in petitioners' Federal income tax return
(return) for each of those years? We hold that he is.
(2) Did petitioners have gross receipts for each of the
years 1987 through 1990 in excess of those reported in Schedule C
of their return for each of those years? We hold that they did.
(3) Are petitioners entitled to deductions under section
162(a) for automobile expenses for each of the years at issue?
We hold that they are not.
(4) Did petitioners place depreciable properties in service
1 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011