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Docket No. 20538-91
Year Deficiency
1987 $21,600
Docket No. 15975-92
Tax Additions to Tax
Year Sec. Sec. Sec. Sec.
Ended Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6661
7/31/88 $808,755 $606,566 50% of -- $202,189
interest due
on $808,755
7/31/89 869,682 -- -- $652,261 217,420
Docket No. 16122-92
Addition to Tax
Year Deficiency Sec. 6653(b)(1)
1988 $1,378,634 $1,078,379
Docket No. 8587-93
Addition to Tax and Penalties
Sec. Sec. Sec.
Year Deficiency 6653(a) 6656(a) 6662(a)
1988 $2,742,859 $137,143 $284,657 --
1989 428,739 -- 52,009 $85,747
Docket No. 8923-93
Tax Additions to Tax and Penalty
Year Sec. Sec. Sec.
Ended Deficiency 6653(a)(1) 6661 6662(a)
11/30/88 $2,526,905 $126,345 $631,726 --
11/30/89 2,929,741 -- -- $585,948
After concessions, the issues remaining for decision are:
(1) Whether amounts deducted as management and consulting fees
are reasonable payments for services rendered; (2) whether the
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Last modified: May 25, 2011