-2-
1988 121,986 --- 92,640 --- --- --- 30,497 ---
1989 110,248 $27,562 --- --- --- --- --- $82,686
1 50 percent of the interest due on the portion of the underpayment due to fraud.
Respondent determined the following additions to tax and penalty
in the alternative:
Additions to Tax and Penalty
Sec. Sec. Sec. Sec. Sec.
6651 6653 6653 6653 6653 Sec.
Year Deficiency (a)(1) (a)(1) (a)(2) (a)(1)(A) (a)(1)(B) 6662
1985 $34,812 $3,885 $2,377 1 --- --- ---
1986 247,288 61,822 --- --- $12,801 1 ---
1987 46,021 --- --- --- 2,823 1 ---
1988 121,986 --- 6,176 --- --- --- ---
1989 110,248 --- --- --- --- --- $22,050
1 50 percent of the interest due on the deficiency.
After concessions, the issues remaining for our
consideration are: (1) Whether petitioner failed to include
$208,994 in income for 1986; (2) whether petitioner is entitled
to a capital or ordinary loss in connection with funds advanced
to a business enterprise and, if so, in which year; (3) whether
petitioner is entitled to losses claimed in connection with
leasing transactions; (4) whether petitioner overstated his
alimony deduction by $11,988 for each of the 1985 through 1989
taxable years; (5) whether petitioner is entitled to claim a loss
from real estate activity and, if so, the character of such a
loss; (6) whether petitioner is liable for an addition to tax for
fraud or, alternatively, an addition to tax for negligence and/or
delinquency for any of the 1985 through 1988 taxable years;
(7) whether petitioner is liable for an addition to tax for
substantially understating his income tax for any of the 1985
through 1988 taxable years; (8) whether petitioner is liable for
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