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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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