- 2 - determination for Mrs. Sparrow, and respondent reflected each of these determinations in separate notices of deficiency. Respondent determined the following deficiencies in, and additions to, petitioners’ taxes: Robert D. Sparrow, docket No. 7127-94 Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6661 1986 $12,742 --- $9,557 $3,186 1987 71,509 --- 53,632 17,877 1988 49,835 $37,376 --- 12,459 N. LaRae Sparrow, docket No. 7128-94 Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1) 6661 1986 $12,742 $3,186 $3,186 1987 71,742 --- 17,877 1988 49,835 12,459 12,459 Respondent also determined that Mr. Sparrow was liable for the addition to tax under section 6653(b)(1)(B) on the entire deficiency for 1986 and 1987, and that petitioners were liable for increased interest under section 6621(c) on the entire deficiency in each year. Following a consolidation of the cases, we must decide: 1. Whether petitioners underreported their gross income for 1986, 1987, and 1988, by failing to report proceeds from the sales of stock. We hold they did. 2. Whether petitioners failed to report $10,000 in consulting fees received by Mr. Sparrow in 1986, and, if theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011