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Kenneth S. Sussmane, for petitioner.
Albert G. Kobylarz and Guy G. LaVignera, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: These three cases have been consolidated
for trial, briefing and opinion. Respondent, by three notices of
deficiency, determined deficiencies in, and additions to,
petitioner's Federal income tax, as well as a penalty, as
follows:
Additions to Tax and Penalties
Docket Sec. Sec. Sec. Sec. Sec.
No. Year Deficiency 6653(a) 6653(a)(1)(A) 6653(a)(1)(B) 6661 6662(a)
5780-92 1988 $168,900 $8,445 --- --- $42,225 ---
21777-93 1987 157,105 ---$7,855 * 39,276 ---
592-94 1989 44,728 --- --- --- --- $8,946
* 50 percent of the interest due on $157,105.
Respondent first issued a notice of deficiency for 1988. In
that notice of deficiency, respondent explained that the basis
for the adjustment giving rise to substantially all of the
deficiency in tax was that petitioner had failed to establish a
nontaxable source for funds used in his "casino activities".
Subsequently, respondent issued notices of deficiency for 1987
and 1989. The basis for the adjustments made in those notices of
deficiency is that petitioner, an attorney, failed to report as
income a certain fee earned by him. On brief, respondent
concedes that the three notices of deficiency are to be
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