J.J. Zand - Page 7

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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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