Patricia S. Makalintal - Page 14

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          on Mr. Makalintal and petitioner’s 1988 joint Federal income tax            
          return.1                                                                    
               Based on the trial evidence, respondent has adjusted                   
          downward the unreported income that she now claims, under her               
          bank deposits analyses, should be charged to Mr. Makalintal and             
          petitioner for 1987 and 1988 from $690,922 and $969,584,                    
          respectively, to $501,134 and $332,601, respectively.                       
               For 1986, 1987, and 1988, respondent also determined against           
          Mr. Makalintal and petitioner additions to tax for negligence               
          under section 6653(a) and for substantial understatements under             
          section 6661.                                                               
               As indicated, Mr. Makalintal apparently now resides in the             
          Philippines, is divorced from petitioner, and apparently is                 
          ignoring his obligations to petitioner and his children under the           
          divorce decree and property settlement agreement and his                    
          obligations to respondent under the notices of deficiency mailed            
          to him for the years in dispute.                                            

                                       OPINION                                        
          1986 Income from Sale of ICPI Stock and                                     
          Respondent’s Bank Deposit Analyses                                          
               Section 453 provides generally that income from an                     
          installment sale shall be taken into account under the                      


          1    The parties have stipulated that the $31,335 home mortgage             
          interest expense deduction claimed on Mr. Makalintal and                    
          petitioner’s 1988 joint Federal income tax return was improper.             




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