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(4) Is petitioner liable for 1986 for the addition to tax
under section 6661(a)? We hold that he is to the extent stated
herein.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Washington, D.C.
During 1984, petitioner was employed as general manager of
Linea Pitti (Linea Pitti), an exclusive clothing store located in
the Georgetown Park shopping center (Georgetown Park) in Washing-
ton, D.C., and received $23,428.85 from that employment. During
that year, petitioner was also employed by Eduardo, Inc., another
clothing store located in Georgetown Park, and received $4,127.99
from that employment.
In July 1984, petitioner purchased a residence located on
West Beach Drive, N.W., in Washington, D.C. In connection with
that purchase, petitioner borrowed $156,750 that he was to repay
in monthly installments of $1,672.93.
Petitioner reported the total wages that he received during
1984 from Linea Pitti and Eduardo, Inc. in the return that he
filed for that year. He reported no other income in his 1984
return. In that return, petitioner claimed the following deduc-
tions: $4,009 in home mortgage interest, $530 in credit card
interest, $2,131 in State and local income, real property, and
sales taxes, and $108 in charitable contributions.
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