- 14 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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