-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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011