T.C. Memo. 1996-225
UNITED STATES TAX COURT
JAMES K. ROBERTS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10322-93. Filed May 16, 1996.
The issues for decision are (1) whether
petitioner failed to report certain items of gross
income, (2) whether he is entitled to certain
disallowed Schedule C and Schedule A deductions, and
(3) whether he is liable for certain additions to tax.
1. Held: Except for one item, P has failed to
prove that the income items in dispute were not gross
income to him.
2. Held, further, P is not entitled to any of the
disputed deductions disallowed by R.
3. Held, further, R’s determination of the
disputed addition to tax under sec. 6651, I.R.C., is
sustained.
4. Held, further, R’s determination of additions
to tax under sec. 6653(a), I.R.C., is sustained.
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