Stanley P. Zurn - Page 2

                                         -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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