James K. Roberts - Page 2

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                    5.  Held, further, R’s determination of additions                 
               to tax under sec. 6661, I.R.C., is sustained.                          


               Samuel G. Weiss, for petitioner.                                       
              Jody Tancer and Mark A. Ericson, for respondent.                       


                                 MEMORANDUM OPINION                                   
               HALPERN, Judge:  By notice of deficiency dated February 26,            
          1993 (the notice of deficiency), respondent determined                      
          deficiencies in income tax and additions to tax as follows:                 
                              Additions to Tax                                        
                                        Sec.                                          
                              Sec.      6653(a)(1)       Sec.    Sec.                 
          Year      Deficiency6651(a)(1)or (a)(1)(A)   6653(a)(1)(B)6661                 
          1986      $7,267        $617  $394      50% of interest$1,817               
                                                  due on $7,267                       
          1987      24,372    1,522     2,127     50% of interest6,072                
                                                  due on $24,288                      
          1988      7,632     ---            382       ---       1,908                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years at issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               Each of the parties has conceded certain issues, and the               
          parties have agreed to the resolution of certain other issues.              
          The issues remaining 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 remaining              
          additions to tax.  The parties have stipulated numerous facts,              





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