Robert D. Sparrow - Page 2

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          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 they               




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