- 2 - LARO, Judge: This case was submitted to the Court without trial. Rule 122(a). Robert Libutti petitioned the Court to redetermine respondent's determinations with respect to his 1987, 1988, and 1989 Federal income taxes. Respondent determined that petitioner was liable for the following income tax deficiencies, additions to tax for delinquent filings under section 6651(a)(1), additions to tax for substantial understatements of income tax under section 6661, and an accuracy-related penalty for substantial understatement of income tax under section 6662(a), (b)(2), and (d): Additions to Tax Penalty Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6661 6662 1987 $171,386 $347,673 $42,666 --- 1988 272,298 125,036 68,075 --- 1989 314,792 27,297 --- $62,958 Following petitioner’s concession in his opening brief that he is subject to the additions to tax under section 6651(a)(1),1 we must decide whether petitioner can deduct gambling losses to the extent of the value of "complimentary" goods and services 1 Petitioner states in his brief that he cannot prove the filing date of his 1987 or 1988 tax return. We consider this statement as petitioner's concession of the allegation in his pleading that the notice of deficiency as it relates to 1987 and 1988 is time barred under sec. 6501(a). See Rule 142(a); Mecom v. Commissioner, 101 T.C. 374, 381-383 (1993) (discussion of the time bar of sec. 6501(a), including the burden of proof with respect thereto), affd. without published opinion 40 F.3d 385 (5th Cir. 1994).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011