-3-
a fraud penalty or, alternatively, an accuracy-related penalty
for 1989; and (9) whether petitioner is liable for an addition to
tax for failure to timely file his 1989 Federal income tax
return.
Background1
For convenience, findings of fact and legal discussion are
being combined for related issues. Petitioner resided in Los
Angeles, California, at the time the petition in this case was
filed. Petitioner, a high school graduate, completed some
college on a part-time basis. Petitioner was employed by the
City of Los Angeles, Bureau of Street Maintenance, as a
construction crew supervisor. The job involved the use of heavy,
off-road paving and concrete equipment. Petitioner retired from
his city job in 1980 and entered the real estate business.
Petitioner was successful in the real estate business and
had accumulated in excess of 20 rental properties by the close of
1989.
Issue 1. Whether Petitioner Failed To Include Income of $208,994
for 1986
Respondent determined, for 1986, that petitioner's income
should be increased by $325,994 attributable to unexplained bank
deposits, as follows:
1 The parties’ stipulation of facts and exhibits are
incorporated herein by this reference.
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