- 9 - for the years 1977 and 1978, and therefore failed to report other or miscellaneous income for those years in the respective amounts of $2,000,536 and $2,926,612. Relevant portions of the record include the following. Petitioner admits that he sold interests in the S-J partnerships during 1976 and 1977. Petitioner admits that he received substantial amounts of cash from the sales proceeds of the limited partnership interests in the S-J partnerships. Petitioner cannot give an exact accounting of the amount of cash so received, or the time he received the cash. He failed to maintain books and records providing an accurate accounting of the cash he received from these sales. Nevertheless, he admits that he received "approximately $1,720,916". Petitioner admits that he fraudulently failed to report "all or a substantial portion of" the income he received during 1976 and 1977 from the sale of limited partnership interests in the S-J partnerships. Respondent seeks partial summary judgment as to the amount of other or miscellaneous income for 1976 that she determined in the notice of deficiency, $1,684,916.6 Petitioner's admissions establish that over a 2-year period, during 1976 and 1977, he received approximately $1,720,916 in commissions. However, these 6 In the notice of deficiency respondent listed the source of payments by which she determined petitioner's unreported commission income. It is a list of bank deposits referencing the respective banks, account numbers, check numbers, check dates, and amounts. The underlying documentation concerning these items is not included in the record before us on this motion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011