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J.J. Zand and Eva C. Zand, Docket No. 32435-88
Additions to Tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2)
1978 $479,425.94 1$23,971.30 ---
1979 754,569.20 1 37,728.46 ---
1980 171,510.84 1 8,575.54 ---
1981 246,218.55 12,310.93 50 percent of
interest due on
$246,218.55
1 The correct section is 6653(a).
In an Amendment to Answer filed August 13, 1991, respondent
asserted increased deficiencies in, and additions to, petitioner
J.J. Zand's Federal income taxes as follows:
Increase in Increase in Addition to Tax
Year Deficiency Sec. 6653(b)
1973 $5,150.34 $2,575.17
1974 59,729.00 29,864.50
1975 305,317.94 152,658.94
1976 99,952.62 49,976.34
A substantial number of adjustments for most of the years in
issue have been settled by concessions made by the parties.
These concessions can ultimately be reflected in the Rule 155
computations. The following issues are presented for decision:
1. Whether J.J. Zand (petitioner) had unreported commission
or fee income received from contracts for services between him or
his sole proprietorship, Caspian Trading Company, and various
manufacturers.
2. Whether petitioner had unreported commission or fee
income received from contracts between various manufacturers and
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