Lawrence J. Polidori - Page 2

                                        - 2 -                                         
                                              Additions to Tax                       
               Year      Deficiency     Sec. 6661      Sec. 6653 (b)                  
               1980      $113,469       --             $64,650                        
               1981      39,563         --             28,150                         
               1982      40,360         $10,090        25,125                         
               1983      19,561         4,890          9,781                          
               1984      19,286         4,822          9,643                          
               1985      41,813         10,453         20,907                         
               1986      21,143         5,286          12,907                         
               After concessions, the issues for decision are:                        
               (1)  Whether certain deposits to a foreign bank account                
          constitute unreported income to petitioner.  We hold that they              
          do.                                                                         
               (2)  Whether petitioner is liable for additions to tax for             
          fraud under section 6653(b) for 1980 and 1981, under section                
          6653(b)(1) and (2) for 1982 through 1985, and under section                 
          6653(b)(1)(A) and (B) for 1986.  With respect to taxable years              
          1980 through 1984, we hold that he is.  With respect to taxable             
          years 1985 and 1986, we hold that he is not.                                
               (3)  Whether petitioner is liable for the addition to tax              
          under section 6661 for a substantial understatement in income tax           
          for taxable years 1982, 1983, 1984, 1985, and 1986.  To the                 
          extent provided for herein, we hold that he is.                             
               (4)  Whether the period of limitations has expired for                 
          assessment and collection of the deficiencies in and additions to           
          petitioner's Federal income tax for any year at issue.  With                
          respect to taxable years 1980 through 1984, we hold that it has             
          not.  With respect to taxable years 1985 and 1986, we hold that             
          it has.                                                                     



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